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 by CIT - there is a huge difference in invoice value and the duty paid as per the Annexure-15 and the ITS data available -reconciliation should have been sought by Ld. AO during the course of assessment proceedings. Non-seeking of such reconciliation, which apparently should have been sought, in our view, indicates non-application of mind to the given set of facts by Ld. AO during the course of assessment proceedings. - Revision order sustained - AT
Revision u/s 263 by CIT - there is a huge difference in invoice value and the duty paid as per the Annexure-15 and the ITS data available -reconciliation should have been sought by Ld. AO during the course of assessment proceedings. Non-seeking of such reconciliation, which apparently should have been sought, in our view, indicates non-application of mind to the given set of facts by Ld. AO during the course of assessment proceedings. - Revision order sustained - AT
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