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 - As the assessment was completed after making required amount of enquiry and there was no lake of enquiry or investigation by the AO on the issues which was raised by the ld. Pr. CIT under the provision of section 263 proceedings. Therefore, the findings of Ld Pr. CIT that order passed by AO was passed without conducting necessary enquires and without verifying necessary details was without any basis or without any evidence on record and mere guess work that that the ld AO has not conducted the enquiry.- AT
Revision u/s 263 - As the assessment was completed after making required amount of enquiry and there was no lake of enquiry or investigation by the AO on the issues which was raised by the ld. Pr. CIT under the provision of section 263 proceedings. Therefore, the findings of Ld Pr. CIT that order passed by AO was passed without conducting necessary enquires and without verifying necessary details was without any basis or without any evidence on record and mere guess work that that the ld AO has not conducted the enquiry.- AT
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