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...
Revision u/s 263 - Applicability of provisions of 56(2)(vii)(b) - Documentary evidence available in the records which the AO admits to have verified the veracity thereof amply demonstrate that the AO made the requisite enquiry. If that be so, a mere non-discussion or non-mention thereof in the assessment order could not lead to assumption that the AO did not apply his mind or that he had not made inquiry on the issue. - Revision order set aside - AT
Revision u/s 263 - Applicability of provisions of 56(2)(vii)(b) - Documentary evidence available in the records which the AO admits to have verified the veracity thereof amply demonstrate that the AO made the requisite enquiry. If that be so, a mere non-discussion or non-mention thereof in the assessment order could not lead to assumption that the AO did not apply his mind or that he had not made inquiry on the issue. - Revision order set aside - AT
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