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 by CIT - the ITAT upheld the impugned order, dismissing the appeal of the assessee. The Tribunal ruled that the CIT had exercised revisional jurisdiction after independently examining the records and applying their mind to the case. Additionally, they found that the reference made by the Assessing Officer to the TPO was invalid due to the expiration of the time limit, making it no reference in the eyes of the law.
Revision u/s 263 by CIT - the ITAT upheld the impugned order, dismissing the appeal of the assessee. The Tribunal ruled that the CIT had exercised revisional jurisdiction after independently examining the records and applying their mind to the case. Additionally, they found that the reference made by the Assessing Officer to the TPO was invalid due to the expiration of the time limit, making it no reference in the eyes of the law.
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