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...
Retraction of statement given during survey - evidentiary value of statement recorded u/s 131 - Despite the retraction, the initial findings of the CIT(A) were largely upheld, as the tribunal found no concrete evidence supporting the assessee's claims of coercion, aside from the letter of retraction and an affidavit. The assessee was found to have unexplained excess cash and stock discrepancies. The Tribunal noted the lack of complete physical verification of stock during the survey but ultimately confirmed the addition, adjusting the gross profit rate applied from 10% to 8.02%, acknowledging some merit in the assessee's submissions regarding the survey’s conduct.
Retraction of statement given during survey - evidentiary value of statement recorded u/s 131 - Despite the retraction, the initial findings of the CIT(A) were largely upheld, as the tribunal found no concrete evidence supporting the assessee's claims of coercion, aside from the letter of retraction and an affidavit. The assessee was found to have unexplained excess cash and stock discrepancies. The Tribunal noted the lack of complete physical verification of stock during the survey but ultimately confirmed the addition, adjusting the gross profit rate applied from 10% to 8.02%, acknowledging some merit in the assessee's submissions regarding the survey’s conduct.
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