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 - Notice issued u/s 148A(b) - By not considering the reply of the Petitioner dated 31st March, 2022, the mandate of Section 148A(c) of the Act has been violated as it casts a duty on the Assessing Officer, by using the expression ‘shall’, to consider the reply of the petitioner/assessee in response to notice under Section 148A(b) of the Act before making an order under Section 148A(d) of the Act. - orders are quashed and the matter is remanded back to the Assessing Officer for a fresh determination. - HC
Reopening of assessment - Notice issued u/s 148A(b) - By not considering the reply of the Petitioner dated 31st March, 2022, the mandate of Section 148A(c) of the Act has been violated as it casts a duty on the Assessing Officer, by using the expression ‘shall’, to consider the reply of the petitioner/assessee in response to notice under Section 148A(b) of the Act before making an order under Section 148A(d) of the Act. - orders are quashed and the matter is remanded back to the Assessing Officer for a fresh determination. - HC
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