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...
Realignment of profits arising on sale of land parcels - surplus arising on sale of asset - ‘capital gains’ OR ‘business income’ - The CIT(A), in our view, has come to a rational conclusion having regard to the corroborative evidences placed and conduct of the assessee over a period of several years in the past. Long period of holding, utilization of own funds, near absence of any trading activity on land except conversion of land in question are amongst vital pointers to lend support the declared intentions of acquiring the land as capital investments. - AT
Realignment of profits arising on sale of land parcels - surplus arising on sale of asset - ‘capital gains’ OR ‘business income’ - The CIT(A), in our view, has come to a rational conclusion having regard to the corroborative evidences placed and conduct of the assessee over a period of several years in the past. Long period of holding, utilization of own funds, near absence of any trading activity on land except conversion of land in question are amongst vital pointers to lend support the declared intentions of acquiring the land as capital investments. - AT
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