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 Reopening of assessment u/s 147 - Valid approval u/s 151 or not? - If only PCIT had read the report carefully, he would have never come to the conclusion that there is any material before him to treat it as a fit case to issue notice u/s 148 or pass order u/s 148A(d) - The safeguards provided in Sections 148 and 151 were lightly treated by CIT and PCIT - Both of them appear to have taken the duty imposed on them under these provisions as of little importance. - Notice quashed - HC
Validity of Reopening of assessment u/s 147 - Valid approval u/s 151 or not? - If only PCIT had read the report carefully, he would have never come to the conclusion that there is any material before him to treat it as a fit case to issue notice u/s 148 or pass order u/s 148A(d) - The safeguards provided in Sections 148 and 151 were lightly treated by CIT and PCIT - Both of them appear to have taken the duty imposed on them under these provisions as of little importance. - Notice quashed - HC
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