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...
Addition u/s 69A or 69C - WhatsApp documents relied upon - as rightly pointed out by the CIT(A), the details to be found in this WhatsApp document tallies with the dates of borrowings as admitted by the assessee in its books of accounts. - Undoubtedly, this is an incriminatory material, and it is not open for the assessee to challenge the reliance of Revenue on this document, without explaining the existence of contents of the document. - AT
Addition u/s 69A or 69C - WhatsApp documents relied upon - as rightly pointed out by the CIT(A), the details to be found in this WhatsApp document tallies with the dates of borrowings as admitted by the assessee in its books of accounts. - Undoubtedly, this is an incriminatory material, and it is not open for the assessee to challenge the reliance of Revenue on this document, without explaining the existence of contents of the document. - AT
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