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 the issue of levying interest u/s 234B in proceedings u/s 147/148. The AO had enhanced the interest from the date of the original assessment order u/s 143(3) to the date of the order u/s 147. However, as the original demand was already paid and there was no discussion on enhancing interest in the reassessment order, the Tribunal held that interest u/s 234B was not applicable. The CIT(A) misunderstood the issue, stating interest u/s 234B is automatic, but the Tribunal disagreed. Since the demand was paid and no income variation occurred, interest u/s 234B was deemed unnecessary. The Tribunal allowed the assessee's appeal, deleting the interest charged by the AO.
The Appellate Tribunal addressed the issue of levying interest u/s 234B in proceedings u/s 147/148. The AO had enhanced the interest from the date of the original assessment order u/s 143(3) to the date of the order u/s 147. However, as the original demand was already paid and there was no discussion on enhancing interest in the reassessment order, the Tribunal held that interest u/s 234B was not applicable. The CIT(A) misunderstood the issue, stating interest u/s 234B is automatic, but the Tribunal disagreed. Since the demand was paid and no income variation occurred, interest u/s 234B was deemed unnecessary. The Tribunal allowed the assessee's appeal, deleting the interest charged by the AO.
Note: It is a system-generated summary and is for quick reference only.