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...
Validity of orders and notices issued u/s 148 - Quantum of escaped income - determination of period of limitation - There is a complete non-application of mind. The payment of loan by the petitioner could not have been added to the loan amount, which the petitioner claims, was received from unrelated parties - the attempt appears to be to, somehow, take the amount which, according to the AO, escaped assessment, over the threshold limit of Rs. 50 lakhs. - Notice and order quashed - HC
Validity of orders and notices issued u/s 148 - Quantum of escaped income - determination of period of limitation - There is a complete non-application of mind. The payment of loan by the petitioner could not have been added to the loan amount, which the petitioner claims, was received from unrelated parties - the attempt appears to be to, somehow, take the amount which, according to the AO, escaped assessment, over the threshold limit of Rs. 50 lakhs. - Notice and order quashed - HC
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