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...
Deemed income u/s 56(2)(x) - Defective Show cause notice - Addition of Unexplained investment u/s 69 - charged to tax u/s 115BBE - The High Court found that the show cause notice issued to the petitioner was defective as it did not specify whether the stamp duty value was proposed to be treated under Section 56(2)(x)(a) or Section 56(2)(x)(b) of the Act. This lack of specificity deprived the petitioner of a reasonable opportunity to respond effectively. Additionally, the assessment order failed to mention Section 56(2)(x) of the Act in its operative part, indicating a deviation from the grounds stated in the show cause notice. The court emphasized that the issuance of a show cause notice is not an empty formality and serves the purpose of providing a fair opportunity to the affected party.
Deemed income u/s 56(2)(x) - Defective Show cause notice - Addition of Unexplained investment u/s 69 - charged to tax u/s 115BBE - The High Court found that the show cause notice issued to the petitioner was defective as it did not specify whether the stamp duty value was proposed to be treated under Section 56(2)(x)(a) or Section 56(2)(x)(b) of the Act. This lack of specificity deprived the petitioner of a reasonable opportunity to respond effectively. Additionally, the assessment order failed to mention Section 56(2)(x) of the Act in its operative part, indicating a deviation from the grounds stated in the show cause notice. The court emphasized that the issuance of a show cause notice is not an empty formality and serves the purpose of providing a fair opportunity to the affected party.
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