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...
Addition proposed in the draft assessment order as TP adjustment - Non following mandatory provisions of Sec. 144C while issuing draft assessment order - The ITAT found merit in the assessee's argument, holding that the assessment order was void as the AO failed to follow the mandatory procedure laid down under Section 144C of the Act. The ITAT referred to various judicial precedents, including decisions of the Hon’ble Karnataka High Court and other ITAT decisions, supporting this view.
Addition proposed in the draft assessment order as TP adjustment - Non following mandatory provisions of Sec. 144C while issuing draft assessment order - The ITAT found merit in the assessee's argument, holding that the assessment order was void as the AO failed to follow the mandatory procedure laid down under Section 144C of the Act. The ITAT referred to various judicial precedents, including decisions of the Hon’ble Karnataka High Court and other ITAT decisions, supporting this view.
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