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...
Maintainability of appeal against Scrutiny assessment u/s 143(3) or intimation u/s 143(1) - Cause of action - The ITAT notes that the assessment under section 143(3) solely relies on adjustments made in the intimation under section 143(1), with no independent discussion on the assessed income. - However, it is established that the cause of action for the appeal arises from the intimation under section 143(1), and no cause of action arises from the order passed under section 143(3) of the Act. - Ultimately, the appeal filed by the assessee is dismissed.
Maintainability of appeal against Scrutiny assessment u/s 143(3) or intimation u/s 143(1) - Cause of action - The ITAT notes that the assessment under section 143(3) solely relies on adjustments made in the intimation under section 143(1), with no independent discussion on the assessed income. - However, it is established that the cause of action for the appeal arises from the intimation under section 143(1), and no cause of action arises from the order passed under section 143(3) of the Act. - Ultimately, the appeal filed by the assessee is dismissed.
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