Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Validity of reopening of assessment u/s 147 - Mandation of obtaining sanction of JCIT - addition made u/s 68 - It is a well settled legal principle that when a statutory provision requires a certain act to be done by a particular authority in a particular manner, it should be done by that authority in that manner only. Any other authority, be it higher or inferior, cannot substitute the authority prescribed under the statute. The legal principle on this aspect is very much clear and leaves no room for doubt. - AT
Validity of reopening of assessment u/s 147 - Mandation of obtaining sanction of JCIT - addition made u/s 68 - It is a well settled legal principle that when a statutory provision requires a certain act to be done by a particular authority in a particular manner, it should be done by that authority in that manner only. Any other authority, be it higher or inferior, cannot substitute the authority prescribed under the statute. The legal principle on this aspect is very much clear and leaves no room for doubt. - AT
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