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 proceedings u/s 153C - The High Court held that loose sheets and diaries, without corroborative evidence, do not constitute "books of account" and hence cannot be solely relied upon for tax assessment purposes. Additionally, the process of centralizing cases without providing a reasonable opportunity for the assessee to object was found to be in violation of Section 127. The notice under Section 153C was deemed invalid because it did not meet the prerequisites for invoking this section.
Validity of proceedings u/s 153C - The High Court held that loose sheets and diaries, without corroborative evidence, do not constitute "books of account" and hence cannot be solely relied upon for tax assessment purposes. Additionally, the process of centralizing cases without providing a reasonable opportunity for the assessee to object was found to be in violation of Section 127. The notice under Section 153C was deemed invalid because it did not meet the prerequisites for invoking this section.
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