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 - taxability of interest under section 28 of Land Acquisition Act - ‘no enquiry’ or ‘lack of enquiry’ - The ITAT held that, the opinion of the Ld. PCIT that the Ld. AO should have passed the assessment in accordance with the amended law and binding decision in Mahender Pal Narang’s case [2020 (3) TMI 1115 - PUNJAB AND HARYANA HIGH COURT] overlooking the decision of Hon’ble Supreme Court in Ghanshyam’s HUF’s [2009 (7) TMI 12 - SUPREME COURT] case is not sustainable. - The ITAT further observed that, it can at best be said to be a debatable issue on which two views are possible and the Ld. AO accepts one of the views. - Revision order quashed.
Revision u/s 263 - taxability of interest under section 28 of Land Acquisition Act - ‘no enquiry’ or ‘lack of enquiry’ - The ITAT held that, the opinion of the Ld. PCIT that the Ld. AO should have passed the assessment in accordance with the amended law and binding decision in Mahender Pal Narang’s case [2020 (3) TMI 1115 - PUNJAB AND HARYANA HIGH COURT] overlooking the decision of Hon’ble Supreme Court in Ghanshyam’s HUF’s [2009 (7) TMI 12 - SUPREME COURT] case is not sustainable. - The ITAT further observed that, it can at best be said to be a debatable issue on which two views are possible and the Ld. AO accepts one of the views. - Revision order quashed.
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