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...
Non following Procedure laid down u/s 144C - Action of the AO/NeAC not proposing all the variation in the Draft Assessment Order - The Tribunal agrees with the appellant's argument that the AO/NeAC's actions were procedurally flawed, as they proposed additions in the final order without including them in the Draft Assessment Order, thus denying the appellant the opportunity to file objections before the Dispute Resolution Panel. - The ITAT allows the appeal of the assessee, highlighting the procedural irregularities and jurisdictional flaws in the assessment process.
Non following Procedure laid down u/s 144C - Action of the AO/NeAC not proposing all the variation in the Draft Assessment Order - The Tribunal agrees with the appellant's argument that the AO/NeAC's actions were procedurally flawed, as they proposed additions in the final order without including them in the Draft Assessment Order, thus denying the appellant the opportunity to file objections before the Dispute Resolution Panel. - The ITAT allows the appeal of the assessee, highlighting the procedural irregularities and jurisdictional flaws in the assessment process.
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