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 - Period of limitation - doctrine of merger - The revision is on the basis that the AO has failed to, in view of the frequent transactions of purchase and sale of land during the year, as well as in the immediately preceding and succeeding year, as also the fact that the sales are to real estate developer, failed to investigate further, making proper inquiries, from the stand point that the income from these transactions is liable to be assessed as business income, i.e., as against capital gains. We fail to see as to how the doctrine of merger would operate in the instant case to oust the jurisdiction of the revisionary authority. - AT
Revision u/s 263 - Period of limitation - doctrine of merger - The revision is on the basis that the AO has failed to, in view of the frequent transactions of purchase and sale of land during the year, as well as in the immediately preceding and succeeding year, as also the fact that the sales are to real estate developer, failed to investigate further, making proper inquiries, from the stand point that the income from these transactions is liable to be assessed as business income, i.e., as against capital gains. We fail to see as to how the doctrine of merger would operate in the instant case to oust the jurisdiction of the revisionary authority. - AT
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