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...
Correct head of income - compensation/liquidation damages received on account of relinquishment of right in the property - The word saleable condition cannot be a deciding factor that the assessee wanted to acquire the project for its business activities. Admittedly, it appears to us that the scale of the business of the assessee was not significant enough to acquire such a huge property for its business activities and similarly there was not sufficient funds available with it which is discernible from the financial statement of the assessee. But, again we are not in agreement with the decision of the authorities below on this aspect. The assessee might have some financier or exploring for some joint-venture. - the amount of compensation received by the assessee is not chargeable to tax in the hands of the assessee. - AT
Correct head of income - compensation/liquidation damages received on account of relinquishment of right in the property - The word saleable condition cannot be a deciding factor that the assessee wanted to acquire the project for its business activities. Admittedly, it appears to us that the scale of the business of the assessee was not significant enough to acquire such a huge property for its business activities and similarly there was not sufficient funds available with it which is discernible from the financial statement of the assessee. But, again we are not in agreement with the decision of the authorities below on this aspect. The assessee might have some financier or exploring for some joint-venture. - the amount of compensation received by the assessee is not chargeable to tax in the hands of the assessee. - AT
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