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...
Addition on account of excess stock of jewellery found during survey - addition u/s 69A and not under Income from Business - On a careful reading of the specific reasons for surrendering the income wherein very clearly the assessee states that; "it is submitted that certain discrepancies were observed related to cash deposit/income etc. However, is, order to by peace of mind and to avoid any litigation and is order to settle the group cases of the persons covered " - The wordings are very clear and categoric. We have taken into consideration the PMGKY Scheme 2016 and have also taken into consideration two Circulars which clarify those i.e. Circular No. 2/2017 and 9/2017. - Additions deleted - AT
Addition on account of excess stock of jewellery found during survey - addition u/s 69A and not under Income from Business - On a careful reading of the specific reasons for surrendering the income wherein very clearly the assessee states that; "it is submitted that certain discrepancies were observed related to cash deposit/income etc. However, is, order to by peace of mind and to avoid any litigation and is order to settle the group cases of the persons covered " - The wordings are very clear and categoric. We have taken into consideration the PMGKY Scheme 2016 and have also taken into consideration two Circulars which clarify those i.e. Circular No. 2/2017 and 9/2017. - Additions deleted - AT
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