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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...
The ITAT Chennai considered a case involving a Best Judgment Assessment conducted u/s. 144 due to the assessee's failure to file a return within the specified time u/s. 142(1). The AO treated the return as 'invalid' and proceeded with the assessment. The intimation u/s. 143(1) by CPC, Bangalore did not regularize the return, as the AO explicitly deemed it invalid. The assessment without a notice u/s. 143(2) was upheld as valid. Regarding cash deposits during demonetization, the assessee failed to provide sufficient explanation, leading to confirmation of the addition. Profit rate determination at 8% on total turnover was upheld due to lack of evidence or explanation. The appeal on these issues was dismissed.
The ITAT Chennai considered a case involving a Best Judgment Assessment conducted u/s. 144 due to the assessee's failure to file a return within the specified time u/s. 142(1). The AO treated the return as 'invalid' and proceeded with the assessment. The intimation u/s. 143(1) by CPC, Bangalore did not regularize the return, as the AO explicitly deemed it invalid. The assessment without a notice u/s. 143(2) was upheld as valid. Regarding cash deposits during demonetization, the assessee failed to provide sufficient explanation, leading to confirmation of the addition. Profit rate determination at 8% on total turnover was upheld due to lack of evidence or explanation. The appeal on these issues was dismissed.
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