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 by CIT - Even if we agrees to the contention of the Ld. A.R. of the assessee that Explanation 2(c ) below section 263(1) of the Act is not applicable for AY 2014-15, still it does not in any way make any impact on the finding made by the Ld. PCIT that the AO has not enquired into the five (5) issues raised by him in the SCN - we uphold the action of the Ld. PCIT to have invoked Section 263 of the Act to interdict the assessment order - AT
Revision u/s 263 by CIT - Even if we agrees to the contention of the Ld. A.R. of the assessee that Explanation 2(c ) below section 263(1) of the Act is not applicable for AY 2014-15, still it does not in any way make any impact on the finding made by the Ld. PCIT that the AO has not enquired into the five (5) issues raised by him in the SCN - we uphold the action of the Ld. PCIT to have invoked Section 263 of the Act to interdict the assessment order - AT
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