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...
Appealable order before CIT(A) - scope of order passed on the basis of direction given u/s 263, revisionary proceedings - Therefore, for all purposes, the computation of income by the AO giving effect to the ld. CIT’s direction is an assessment order which is appealable. The order passed by the CIT(A), we hold, therefore, holding the assessment order to be not appealable is incorrect in law. Having held so, we deem it fit to restore the issue back to the AO to verify the facts of the case and thereafter pass an order in accordance with the directions of the CIT in his order passed u/s 263 - AT
Appealable order before CIT(A) - scope of order passed on the basis of direction given u/s 263, revisionary proceedings - Therefore, for all purposes, the computation of income by the AO giving effect to the ld. CIT’s direction is an assessment order which is appealable. The order passed by the CIT(A), we hold, therefore, holding the assessment order to be not appealable is incorrect in law. Having held so, we deem it fit to restore the issue back to the AO to verify the facts of the case and thereafter pass an order in accordance with the directions of the CIT in his order passed u/s 263 - AT
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