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 - Non deduction of TDS u/s 194C - reliance on audit objection - it is evident from the assessment order that the AO had already scrutinized the expenses claimed by the assessee during the original assessment. While so, reopening the assessment solely on the basis of an audit objection amounts to a clear case of change of opinion, as observed by the Tribunal. - HC
Reopening of assessment - Non deduction of TDS u/s 194C - reliance on audit objection - it is evident from the assessment order that the AO had already scrutinized the expenses claimed by the assessee during the original assessment. While so, reopening the assessment solely on the basis of an audit objection amounts to a clear case of change of opinion, as observed by the Tribunal. - HC
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