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 Income Tax Settlement order - additions made with respect to the infusion of share capital and the denial of benefit of deductions u/s 80IC - second round of litigation - The Court found substantial merit in the assessee's submissions regarding the infusion of share capital. The Court concluded that the addition of INR 11.26 crores by the ITSC was unsubstantiated, especially in light of evidence suggesting the funds' availability for such investment by the implicated company in the relevant assessment years. - The High Court observed a pivotal mistake in the ITSC's handling of share capital issues, particularly failing to account for the Department's contradictory stances and the non-application of Section 115BBE of the Act, which pertains to tax on income with unexplained credit.
Validity of Income Tax Settlement order - additions made with respect to the infusion of share capital and the denial of benefit of deductions u/s 80IC - second round of litigation - The Court found substantial merit in the assessee's submissions regarding the infusion of share capital. The Court concluded that the addition of INR 11.26 crores by the ITSC was unsubstantiated, especially in light of evidence suggesting the funds' availability for such investment by the implicated company in the relevant assessment years. - The High Court observed a pivotal mistake in the ITSC's handling of share capital issues, particularly failing to account for the Department's contradictory stances and the non-application of Section 115BBE of the Act, which pertains to tax on income with unexplained credit.
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