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 - Addition u/s 69C on account of the capital introduced by the partner and unsecured loans - The Tribunal upheld the validity of the reassessment proceedings, citing the absence of a request for reasons during the assessment or appellate proceedings. However, it ruled in favor of the Assessee regarding the additions under section 69C. The Tribunal emphasized the Assessee's compliance with providing evidence and shifted the onus to the AO to justify rejecting the explanations provided.
Validity of reopening of assessment u/s 147 - Reason to believe - Addition u/s 69C on account of the capital introduced by the partner and unsecured loans - The Tribunal upheld the validity of the reassessment proceedings, citing the absence of a request for reasons during the assessment or appellate proceedings. However, it ruled in favor of the Assessee regarding the additions under section 69C. The Tribunal emphasized the Assessee's compliance with providing evidence and shifted the onus to the AO to justify rejecting the explanations provided.
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