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...
Reopening of assessment u/s 147 - assessment is in pursuance of an order on appeal, etc. u/s 150 - Already order of the Tribunal has been given effect to by the assessing officer for the assessment year 1995-96 by the consequential order dated 21.12.2005. That being the position, it was not open to the assessing officer to have once again issued a notice under Section 148 r.w.s. 150 of the Act to reopen the assessment for the assessment year 1995-96, that too, on a different issue unconnected with the order of the Tribunal. - HC
Reopening of assessment u/s 147 - assessment is in pursuance of an order on appeal, etc. u/s 150 - Already order of the Tribunal has been given effect to by the assessing officer for the assessment year 1995-96 by the consequential order dated 21.12.2005. That being the position, it was not open to the assessing officer to have once again issued a notice under Section 148 r.w.s. 150 of the Act to reopen the assessment for the assessment year 1995-96, that too, on a different issue unconnected with the order of the Tribunal. - HC
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