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...
Reopening of assessment - The High Court held that no case for reason to believe was made out by the AO. They observed a lack of application of mind in the reasons recorded for reopening the assessment. It was noted that the information relied upon by the AO contained inaccuracies, indicating a non-application of mind. - The Court found that the AO did not address the factual positions asserted by the petitioner in their objections, further indicating a lack of proper consideration. - Ultimately, the Court concluded that the reassessment proceedings were initiated on incorrect facts and lacked jurisdiction, thus quashing the impugned notices and order.
Reopening of assessment - The High Court held that no case for reason to believe was made out by the AO. They observed a lack of application of mind in the reasons recorded for reopening the assessment. It was noted that the information relied upon by the AO contained inaccuracies, indicating a non-application of mind. - The Court found that the AO did not address the factual positions asserted by the petitioner in their objections, further indicating a lack of proper consideration. - Ultimately, the Court concluded that the reassessment proceedings were initiated on incorrect facts and lacked jurisdiction, thus quashing the impugned notices and order.
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