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...
Reopening of assessment u/s 147 - Addition of on-money received by the assessee on sale of land - the sale consideration qua the transaction of sale of land in question, as disclosed in the registered sale deed, could not have been dislodged by the A.O on the basis of the contents of an uncertified copy of an “agreement to sell”, which on the basis of our aforesaid observations would not even be in the nature of a secondary evidence within the meaning of Sec. 63 of the Indian Evidence Act, 1872. - AT
Reopening of assessment u/s 147 - Addition of on-money received by the assessee on sale of land - the sale consideration qua the transaction of sale of land in question, as disclosed in the registered sale deed, could not have been dislodged by the A.O on the basis of the contents of an uncertified copy of an “agreement to sell”, which on the basis of our aforesaid observations would not even be in the nature of a secondary evidence within the meaning of Sec. 63 of the Indian Evidence Act, 1872. - AT
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