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...
Validity assessment proceedings u/s 153C - recording of satisfaction - The ITAT examined the language of Section 153C and referenced the judgment in Ganpati Fincap Services P. Ltd & Ors v. Commissioner of Income Tax. It concluded that only one satisfaction note is required, even if the Assessing Officer of the searched person and the other person is the same. The satisfaction note must confirm that the seized documents belong to the other person, fulfilling the requirements of Section 153C. - It was clarified that the failure of the Assessing Officer of the searched person to make a note in the file of the searched person after transmitting documents to the Assessing Officer of the other person does not invalidate the proceedings under Section 153C.
Validity assessment proceedings u/s 153C - recording of satisfaction - The ITAT examined the language of Section 153C and referenced the judgment in Ganpati Fincap Services P. Ltd & Ors v. Commissioner of Income Tax. It concluded that only one satisfaction note is required, even if the Assessing Officer of the searched person and the other person is the same. The satisfaction note must confirm that the seized documents belong to the other person, fulfilling the requirements of Section 153C. - It was clarified that the failure of the Assessing Officer of the searched person to make a note in the file of the searched person after transmitting documents to the Assessing Officer of the other person does not invalidate the proceedings under Section 153C.
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