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...
Reopening of assessment u/s 147 - appropriate authority for issuance of the notice - The High Court found merit in the petitioner's argument regarding the lack of jurisdictional authority for issuing the notices. It relied on the decision in Twylight Infrastructure Pvt. Ltd. v. ITO & Ors. and ruled in favor of the petitioner. While the petitioner raised concerns about the reassessment proceedings being based on a change of opinion, the High Court's decision primarily focused on the jurisdictional issue.
Reopening of assessment u/s 147 - appropriate authority for issuance of the notice - The High Court found merit in the petitioner's argument regarding the lack of jurisdictional authority for issuing the notices. It relied on the decision in Twylight Infrastructure Pvt. Ltd. v. ITO & Ors. and ruled in favor of the petitioner. While the petitioner raised concerns about the reassessment proceedings being based on a change of opinion, the High Court's decision primarily focused on the jurisdictional issue.
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