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...
Rejection application for Revision u/s 264 in favor of assessee - Rejection on the ground the assessee has filing an appeal u/s 246 which was rejected by the CIT(A) due to non-payment of tax - the order passed by the 2nd respondent, in rejecting the appeal as void ab initio, cannot be considered as disposing the appeal by any of the above modes specified. Thus, it cannot be said that the order of assessment of the 3rd respondent is “subject of an appeal” placing embargo/ousting the jurisdiction of the 1st respondent under Section 264(4). - HC
Rejection application for Revision u/s 264 in favor of assessee - Rejection on the ground the assessee has filing an appeal u/s 246 which was rejected by the CIT(A) due to non-payment of tax - the order passed by the 2nd respondent, in rejecting the appeal as void ab initio, cannot be considered as disposing the appeal by any of the above modes specified. Thus, it cannot be said that the order of assessment of the 3rd respondent is “subject of an appeal” placing embargo/ousting the jurisdiction of the 1st respondent under Section 264(4). - HC
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