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...
Revision u/s 263 - belated employee’s contribution to PF and ESIC funds - AO did not follow the CBDT circular but followed the HC decision - The CIT in exercise the powers vested u/s 263 of the Act cannot do something, what the Assessing Officer himself cannot do. Thus, the very premises on which revision was sought to be made by ld. PCIT had failed, and resultant order has no legs to stand. - AT
Revision u/s 263 - belated employee’s contribution to PF and ESIC funds - AO did not follow the CBDT circular but followed the HC decision - The CIT in exercise the powers vested u/s 263 of the Act cannot do something, what the Assessing Officer himself cannot do. Thus, the very premises on which revision was sought to be made by ld. PCIT had failed, and resultant order has no legs to stand. - AT
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