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...
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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 - Sure, the AO having not considered this aspect of the matter at all, there was no occasion for the assessee to clarify anything thereto, much less qua the date of transfer, which forms the fulcrum of his case/s. It does not, however, lie in the mouth of the assessee, who “explained” the source of the investment in property purchased during the year, to contend that the date of the said purchase falls in the immediately preceding year i.e., in the facts and circumstances of the case and the law in the matter. - Revision proceedings sustained - AT
Revision u/s 263 - Sure, the AO having not considered this aspect of the matter at all, there was no occasion for the assessee to clarify anything thereto, much less qua the date of transfer, which forms the fulcrum of his case/s. It does not, however, lie in the mouth of the assessee, who “explained” the source of the investment in property purchased during the year, to contend that the date of the said purchase falls in the immediately preceding year i.e., in the facts and circumstances of the case and the law in the matter. - Revision proceedings sustained - AT
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