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...
The Appellate Tribunal addressed a case involving revision u/s 263 by PCIT questioning the recognition of liabilities 'Nardana Claim-1' and 'Nardana Claim-2' under ICDS. The Tribunal found that AO adequately investigated the issues through queries and responses from the assessee, rejecting PCIT's claim of lack of investigation. The Tribunal upheld the assessee's explanation that the liabilities were not recognized as income due to pending court disputes, following a court decision on income accrual. Citing Malabar Industries Co. Ltd., the Tribunal held that AO's view favoring the assessee was valid. PCIT's revision based on ICDS violations was deemed unsustainable, leading to the quashing of the revision order and restoration of the AO's assessment order. Assessee's appeal was allowed.
The Appellate Tribunal addressed a case involving revision u/s 263 by PCIT questioning the recognition of liabilities 'Nardana Claim-1' and 'Nardana Claim-2' under ICDS. The Tribunal found that AO adequately investigated the issues through queries and responses from the assessee, rejecting PCIT's claim of lack of investigation. The Tribunal upheld the assessee's explanation that the liabilities were not recognized as income due to pending court disputes, following a court decision on income accrual. Citing Malabar Industries Co. Ltd., the Tribunal held that AO's view favoring the assessee was valid. PCIT's revision based on ICDS violations was deemed unsustainable, leading to the quashing of the revision order and restoration of the AO's assessment order. Assessee's appeal was allowed.
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