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...
Additions towards Undisclosed profit from contract work and transport income - The tribunal found that the assumptions made by Ld. AO are without any basis, on the contrary the basis adopted by the Ld. AO was itself conflicting at places when the percentage of profit was calculated on the basis of turnover in 26AS, but have presumed that the turnover shown in 26AS was not considered by the assessee in the returned income, Ld. AO also presumed that the deemed profit u/s 44AE was not included in the profit shown by the assessee in ITR was again on the basis of presumption without any concrete evidence. - Matter restored back for fresh consideration.
Additions towards Undisclosed profit from contract work and transport income - The tribunal found that the assumptions made by Ld. AO are without any basis, on the contrary the basis adopted by the Ld. AO was itself conflicting at places when the percentage of profit was calculated on the basis of turnover in 26AS, but have presumed that the turnover shown in 26AS was not considered by the assessee in the returned income, Ld. AO also presumed that the deemed profit u/s 44AE was not included in the profit shown by the assessee in ITR was again on the basis of presumption without any concrete evidence. - Matter restored back for fresh consideration.
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