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...
Condonation of delay - delay of 1607 days in filing the appeal by the assessee before ITAT - The Tribunal acknowledged the significant delay but emphasized that the length of the delay should not be the sole determining factor. It considered the reasons provided by the assessee, including ill health and financial stress, and compared the delay to similar cases where longer delays had been condoned. Ultimately, the Tribunal found sufficient cause for the delay and decided to condone it. - Regarding the addition u/s 69, the Tribunal noted that the orders of the AO and CIT(Appeals) were ex-parte. It directed the case to be restored to the file of the Assessing Officer for fresh adjudication.
Condonation of delay - delay of 1607 days in filing the appeal by the assessee before ITAT - The Tribunal acknowledged the significant delay but emphasized that the length of the delay should not be the sole determining factor. It considered the reasons provided by the assessee, including ill health and financial stress, and compared the delay to similar cases where longer delays had been condoned. Ultimately, the Tribunal found sufficient cause for the delay and decided to condone it. - Regarding the addition u/s 69, the Tribunal noted that the orders of the AO and CIT(Appeals) were ex-parte. It directed the case to be restored to the file of the Assessing Officer for fresh adjudication.
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