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 or u/s 153C - validity of proceedings - The High Court emphasized the need for the Assessing Officer to properly apply relevant provisions of the Income Tax Act. It suggested a thorough examination of whether Section 153(C) should have been invoked instead of Sections 147 and 148, especially considering the circumstances of the case. The Court highlighted the importance of procedural fairness and the duty of the Assessing Officer to provide all necessary documents and material to the Assessee. It emphasized the need for compliance with procedural safeguards to ensure a fair assessment process.
Reopening of assessment u/s 147 or u/s 153C - validity of proceedings - The High Court emphasized the need for the Assessing Officer to properly apply relevant provisions of the Income Tax Act. It suggested a thorough examination of whether Section 153(C) should have been invoked instead of Sections 147 and 148, especially considering the circumstances of the case. The Court highlighted the importance of procedural fairness and the duty of the Assessing Officer to provide all necessary documents and material to the Assessee. It emphasized the need for compliance with procedural safeguards to ensure a fair assessment process.
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