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 of Reopening of assessment - acquisition of immovable property jointly - husband’s assessment in hands of wife - The court quashed and set aside the order dated 31st March 2023 passed under Section 148A(d) of the Act. The court concluded that it was not a suitable case for reopening the assessment concerning the petitioner. The court highlighted the lack of necessity in seeking details from the petitioner regarding the source of funds, given that it was established that she had no involvement in the transactions. Moreover, the court noted the surprising behavior of the Principal Chief Commissioner of Income Tax, who sanctioned the issuance of the order instead of directing the assessing officer to drop the proceedings against the petitioner.
Validity of Reopening of assessment - acquisition of immovable property jointly - husband’s assessment in hands of wife - The court quashed and set aside the order dated 31st March 2023 passed under Section 148A(d) of the Act. The court concluded that it was not a suitable case for reopening the assessment concerning the petitioner. The court highlighted the lack of necessity in seeking details from the petitioner regarding the source of funds, given that it was established that she had no involvement in the transactions. Moreover, the court noted the surprising behavior of the Principal Chief Commissioner of Income Tax, who sanctioned the issuance of the order instead of directing the assessing officer to drop the proceedings against the petitioner.
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