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 of expenditure and depreciation but no revenue has been earned - Pr.CIT has directed the AO to make further enquiry on the admissibility of expenditure - Except for an endeavour to embark upon a fishing & roving enquiry, there is no merit in the order passed by ld. Pr.CIT. In our considered opinion, the basic premise on which Pr.CIT has invoked his jurisdiction u/s 263 is legally not sustainable. - AT
Revision u/s 263 - claim of deduction of expenditure and depreciation but no revenue has been earned - Pr.CIT has directed the AO to make further enquiry on the admissibility of expenditure - Except for an endeavour to embark upon a fishing & roving enquiry, there is no merit in the order passed by ld. Pr.CIT. In our considered opinion, the basic premise on which Pr.CIT has invoked his jurisdiction u/s 263 is legally not sustainable. - AT
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