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 - non-application of mind by AO - Borrowed satisfaction - Reliance on investigation initiated by Directorate General of Goods and Services Tax (“DG GST”) - The court observed that both the AO and the PCIT failed to properly assess the information and circumstances before approving the reopening notice. They did not adequately verify the petitioner's compliance with disclosure requirements or consider the timing constraints for issuing such notices. This lack of diligence amounted to a total non-application of mind, rendering the approval and subsequent proceedings unsustainable.
Reopening of assessment - non-application of mind by AO - Borrowed satisfaction - Reliance on investigation initiated by Directorate General of Goods and Services Tax (“DG GST”) - The court observed that both the AO and the PCIT failed to properly assess the information and circumstances before approving the reopening notice. They did not adequately verify the petitioner's compliance with disclosure requirements or consider the timing constraints for issuing such notices. This lack of diligence amounted to a total non-application of mind, rendering the approval and subsequent proceedings unsustainable.
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