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...
Revision u/s 263 - Suo moto revisional proceeding initiated - The Gauhati High Court allowed the writ petition and set aside the Show Cause Notice and the ex-parte Order issued u/s 263 for the assessment year 2017-18. The Court concluded that the initiation of proceedings was illegal, arbitrary, and without jurisdiction. The assessment order, even if erroneous, was not prejudicial to the revenue, as the discrepancy in long-term capital gains was related to exempt income. The judgment reaffirmed the necessity of both conditions being met for the exercise of revisional jurisdiction and emphasized adherence to principles of natural justice.
Revision u/s 263 - Suo moto revisional proceeding initiated - The Gauhati High Court allowed the writ petition and set aside the Show Cause Notice and the ex-parte Order issued u/s 263 for the assessment year 2017-18. The Court concluded that the initiation of proceedings was illegal, arbitrary, and without jurisdiction. The assessment order, even if erroneous, was not prejudicial to the revenue, as the discrepancy in long-term capital gains was related to exempt income. The judgment reaffirmed the necessity of both conditions being met for the exercise of revisional jurisdiction and emphasized adherence to principles of natural justice.
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