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 order passed without dealing with assessee's submission - The Income Tax Appellate Tribunal (ITAT) had previously ruled in favor of the petitioner in a similar case for the assessment year 2011-2012. The High Court affirmed the ITAT's decision, stating that since the members had already paid taxes on the compensation received, there should not be double taxation. The court also emphasized that the petitioner had entered into the development agreement on behalf of its members, and the compensations were meant for them. - s the order failed to consider the petitioner's explanations regarding the nature of the income and its taxability, the court concluded that it could not be sustained.
Validity of reopening order passed without dealing with assessee's submission - The Income Tax Appellate Tribunal (ITAT) had previously ruled in favor of the petitioner in a similar case for the assessment year 2011-2012. The High Court affirmed the ITAT's decision, stating that since the members had already paid taxes on the compensation received, there should not be double taxation. The court also emphasized that the petitioner had entered into the development agreement on behalf of its members, and the compensations were meant for them. - s the order failed to consider the petitioner's explanations regarding the nature of the income and its taxability, the court concluded that it could not be sustained.
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