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 case involved the validity of reopening assessment u/s 147 based on a notice u/s 148. The key issue was the burden of proof regarding credible information to initiate reassessment proceedings. The Appellate Tribunal held that the notice was illegal as the AO failed to provide details of alleged receipt of Rs. 35 Lakh, relying on insufficient information. The burden lies on AOs to verify credibility of information, which was not done in this case. Previous assessment on the same issue with the same entity showed no addition was made, indicating lack of proper examination by the AO. Mere reliance on information without applying mind is unsustainable. Assessee's appeal was allowed.
The case involved the validity of reopening assessment u/s 147 based on a notice u/s 148. The key issue was the burden of proof regarding credible information to initiate reassessment proceedings. The Appellate Tribunal held that the notice was illegal as the AO failed to provide details of alleged receipt of Rs. 35 Lakh, relying on insufficient information. The burden lies on AOs to verify credibility of information, which was not done in this case. Previous assessment on the same issue with the same entity showed no addition was made, indicating lack of proper examination by the AO. Mere reliance on information without applying mind is unsustainable. Assessee's appeal was allowed.
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