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 - since the assessee failed to deduct tax, the A.O was required to make disallowance of interest u/s 40(a)(ia) of the Act on account of non-deduction of TDS. A.O also did not notice that STDR with SBI is not a long term specified asset within the meaning of sec. 54EC of the Act and allowed the claim of the assessee without going through the facts. Therefore, the order passed by the A.O is erroneous and prejudicial to the interest of revenue. - AT
Revision u/s 263 by CIT - since the assessee failed to deduct tax, the A.O was required to make disallowance of interest u/s 40(a)(ia) of the Act on account of non-deduction of TDS. A.O also did not notice that STDR with SBI is not a long term specified asset within the meaning of sec. 54EC of the Act and allowed the claim of the assessee without going through the facts. Therefore, the order passed by the A.O is erroneous and prejudicial to the interest of revenue. - AT
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