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 of assessment u/s 147 - reason to believe - Reply of the assessee through reproduced but the contents thereof are not even referred or analyzed prima facie - The High Court observed that the Assessing Officer had not adequately considered the evidence presented by the petitioner in response to the notice. According to Section 148A(d) of the Income Tax Act, the Assessing Officer is required to decide the validity of issuing a notice based on the material available, including the assessee's reply. However, in this case, the Assessing Officer's decision seemed to ignore the petitioner's evidence.
Validity of Reopening of assessment u/s 147 - reason to believe - Reply of the assessee through reproduced but the contents thereof are not even referred or analyzed prima facie - The High Court observed that the Assessing Officer had not adequately considered the evidence presented by the petitioner in response to the notice. According to Section 148A(d) of the Income Tax Act, the Assessing Officer is required to decide the validity of issuing a notice based on the material available, including the assessee's reply. However, in this case, the Assessing Officer's decision seemed to ignore the petitioner's evidence.
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