Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
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Validity of order passed by PCIT u/s 264 - Non-consideration of submissions of the assessee - Contention of the respondents that it was time barring matter is not acceptable in view of the fact that the relevant assessment order to be revised was received by the petitioner on 4th February, 2020 and as per the statute, limitation is two years from the date of receipt of such assessment order, so, the time for passing the impugned order was becoming barred on 3rd February, 2022 and in view of this fact, the respondent Commissioner could have easily considered the aforesaid objection of the petitioner on 29th March, 2021. There was enough time available to the Commissioner but hastily he passed the impugned order on 29th March, 2021. - HC
Validity of order passed by PCIT u/s 264 - Non-consideration of submissions of the assessee - Contention of the respondents that it was time barring matter is not acceptable in view of the fact that the relevant assessment order to be revised was received by the petitioner on 4th February, 2020 and as per the statute, limitation is two years from the date of receipt of such assessment order, so, the time for passing the impugned order was becoming barred on 3rd February, 2022 and in view of this fact, the respondent Commissioner could have easily considered the aforesaid objection of the petitioner on 29th March, 2021. There was enough time available to the Commissioner but hastily he passed the impugned order on 29th March, 2021. - HC
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