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 the assessment order passed u/s 143(3) - Assumption of jurisdiction to make an assessment - No return of income filed by assessee - Whether a curable defect u/s 292BB - The Assessee argued that as there was no return of income filed at the time of the notice, the assumption of jurisdiction for assessment was flawed. The Department contended that any irregularity in the notice could be cured under section 292BB of the Act. However, the Tribunal found that the notice was issued before the Assessee filed their return of income, rendering the assumption of jurisdiction invalid. Despite the Department's arguments, the Tribunal held that the notice was not in accordance with the Act and could not be cured under section 292BB.
Validity of the assessment order passed u/s 143(3) - Assumption of jurisdiction to make an assessment - No return of income filed by assessee - Whether a curable defect u/s 292BB - The Assessee argued that as there was no return of income filed at the time of the notice, the assumption of jurisdiction for assessment was flawed. The Department contended that any irregularity in the notice could be cured under section 292BB of the Act. However, the Tribunal found that the notice was issued before the Assessee filed their return of income, rendering the assumption of jurisdiction invalid. Despite the Department's arguments, the Tribunal held that the notice was not in accordance with the Act and could not be cured under section 292BB.
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