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 by CIT - disallowance of provision for nonperforming assets (NPA) in computing books profits u/s 115JB - The Tribunal, after considering detailed submissions and previous judicial precedents, ruled in favor of the assessee on all major issues. It concluded that the AO had conducted proper enquiries and made permissible views under the law, rendering the Pr. CIT’s invocation of section 263 invalid. Consequently, the Tribunal quashed the order passed u/s 263 and restored the original assessment order.
Revision u/s 263 by CIT - disallowance of provision for nonperforming assets (NPA) in computing books profits u/s 115JB - The Tribunal, after considering detailed submissions and previous judicial precedents, ruled in favor of the assessee on all major issues. It concluded that the AO had conducted proper enquiries and made permissible views under the law, rendering the Pr. CIT’s invocation of section 263 invalid. Consequently, the Tribunal quashed the order passed u/s 263 and restored the original assessment order.
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