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 satisfaction and proceedings u/s.153C - incriminating material or not - Most of the documents did not pertain to impugned assessment years or does not specify any assessment year or have already recorded in the books of account or a part of assessment years. The documents at least indicate some prima facie that there is same escapement of income or there is an element of undisclosed income, it cannot be said to be incriminating. If the documents found are available in public domain or are statutory records, same cannot be held to be incriminating. - AT
Validity of satisfaction and proceedings u/s.153C - incriminating material or not - Most of the documents did not pertain to impugned assessment years or does not specify any assessment year or have already recorded in the books of account or a part of assessment years. The documents at least indicate some prima facie that there is same escapement of income or there is an element of undisclosed income, it cannot be said to be incriminating. If the documents found are available in public domain or are statutory records, same cannot be held to be incriminating. - AT
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