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...
Reopening of assessment u/s 147 - Eligibility of reasons to believe - there is nothing new and it is, in fact, the very note filed by the assessee as well as material that was available on record that has been invoked by the Assessing Officer to reopen the assessment. The counter filed by the Department makes a lukewarm attempt to defend the impugned proceedings by stating that only a 'half page note' had been filed by the assessee which would not suffice. - This defence is only stated to be rejected. - HC
Reopening of assessment u/s 147 - Eligibility of reasons to believe - there is nothing new and it is, in fact, the very note filed by the assessee as well as material that was available on record that has been invoked by the Assessing Officer to reopen the assessment. The counter filed by the Department makes a lukewarm attempt to defend the impugned proceedings by stating that only a 'half page note' had been filed by the assessee which would not suffice. - This defence is only stated to be rejected. - HC
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