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 - claim of deduction u/s. 54F - The fact remains that the calculations were provided to the ld. PCIT. It is seen that he has failed to find any infirmity in the claim. - PCIT, instead has set aside the order u/s. 143(3)/148 in order to grant one more inning to the Revenue to find some shortcoming in the claim on the suspicion that possibly the AO has missed something in the first round. Such an action cannot be supported. Powers u/s. 263 of the Income Tax Act are not on the Statute for such whimsical and arbitrary actions. - AT
Revision u/s 263 - claim of deduction u/s. 54F - The fact remains that the calculations were provided to the ld. PCIT. It is seen that he has failed to find any infirmity in the claim. - PCIT, instead has set aside the order u/s. 143(3)/148 in order to grant one more inning to the Revenue to find some shortcoming in the claim on the suspicion that possibly the AO has missed something in the first round. Such an action cannot be supported. Powers u/s. 263 of the Income Tax Act are not on the Statute for such whimsical and arbitrary actions. - AT
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