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...
Assessment u/s 153A - Additions made in original assessment u/s 143(3) of the Act again added back in the assessment completed u/s 153A/143(3) , Disallowance of loss incurred by SEZ added u/s 115JB, Disallowance of deduction claimed u/s 35(2AB) , Expenditure by way of tax paid on ESOP added u/s 115JB - The Tribunal's reinforces the necessity of basing additions and disallowances on incriminating material discovered during search operations, especially in unabated assessment years. Furthermore, it emphasizes the importance of evidentiary value and the principles of natural justice in the assessment process. The decision also delineates the boundaries of allowable deductions and the computation of taxable income in light of dubious transactions and flagged suppliers, adhering to established legal precedents.
Assessment u/s 153A - Additions made in original assessment u/s 143(3) of the Act again added back in the assessment completed u/s 153A/143(3) , Disallowance of loss incurred by SEZ added u/s 115JB, Disallowance of deduction claimed u/s 35(2AB) , Expenditure by way of tax paid on ESOP added u/s 115JB - The Tribunal's reinforces the necessity of basing additions and disallowances on incriminating material discovered during search operations, especially in unabated assessment years. Furthermore, it emphasizes the importance of evidentiary value and the principles of natural justice in the assessment process. The decision also delineates the boundaries of allowable deductions and the computation of taxable income in light of dubious transactions and flagged suppliers, adhering to established legal precedents.
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