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 the order passed u/s 147 - insufficient reason to believe - There is no basis mentioned in the reasons for the belief of the Assessing Officer that the assessee’s entire claim of deduction under Section 48 of the Act was incorrect. And this escapement of income has absolutely no link or correlation with the information in the possession of the AO that the other co-owner of land had incorrectly claimed deduction under Section 54B of the Act. - Reassessment order quashed - AT
Validity of the order passed u/s 147 - insufficient reason to believe - There is no basis mentioned in the reasons for the belief of the Assessing Officer that the assessee’s entire claim of deduction under Section 48 of the Act was incorrect. And this escapement of income has absolutely no link or correlation with the information in the possession of the AO that the other co-owner of land had incorrectly claimed deduction under Section 54B of the Act. - Reassessment order quashed - AT
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