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...
Addition u/s 68 - share application money/share capital and share premium as unexplained - The onus was on revenue to dislodge assessee’s documentary evidences and rebut the same by bringing on record any cogent material to demonstrate that assessee’s own money flew back in the shape of share application / share premium - nothing of that sort has been brought on record by Ld. AO. It is trite law that no additions could be made merely on the basis of suspicion, conjectures or surmises - AT
Addition u/s 68 - share application money/share capital and share premium as unexplained - The onus was on revenue to dislodge assessee’s documentary evidences and rebut the same by bringing on record any cogent material to demonstrate that assessee’s own money flew back in the shape of share application / share premium - nothing of that sort has been brought on record by Ld. AO. It is trite law that no additions could be made merely on the basis of suspicion, conjectures or surmises - AT
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