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...
Additions u/s 69C - purview and scope of section 69C is totally different from the disallowance of expenses found to be not genuine - The basic premise with the CIT therefore for finding error in the order of the AO, that the disallowance made by him of contractors’ expense came under the purview of section 69C of the Act is found to be untenable in law. His finding of error, as a consequence whereof, that the same not being subjected to tax at a special rate provided u/s 115BBE of the Act also as a result does not survive. - AT
Additions u/s 69C - purview and scope of section 69C is totally different from the disallowance of expenses found to be not genuine - The basic premise with the CIT therefore for finding error in the order of the AO, that the disallowance made by him of contractors’ expense came under the purview of section 69C of the Act is found to be untenable in law. His finding of error, as a consequence whereof, that the same not being subjected to tax at a special rate provided u/s 115BBE of the Act also as a result does not survive. - AT
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