Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Validity of reopening of assessment u/s 147 - The only contention of the writ applicant is that during the course of the assessment proceedings, the Assessing Officer could not have called for further information by issuing the impugned show cause notice - This contention is thoroughly fallacious and not tenable in view of the scheme of the Act. - The case on hand is not one in which it can be said that the jurisdictional fact did not exist. We should not interfere with the impugned show cause notices - HC
Validity of reopening of assessment u/s 147 - The only contention of the writ applicant is that during the course of the assessment proceedings, the Assessing Officer could not have called for further information by issuing the impugned show cause notice - This contention is thoroughly fallacious and not tenable in view of the scheme of the Act. - The case on hand is not one in which it can be said that the jurisdictional fact did not exist. We should not interfere with the impugned show cause notices - HC
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