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 High Court addressed the issue of reopening assessment due to disallowance of depreciation and reduced returned loss. The notice was issued after the 4-year period, leading to a challenge. The ITAT deemed the reopening as a change of opinion, thus invalid. The Court found that the assessing officer lacked tangible evidence for the reassessment and that the assessee had disclosed all necessary facts. Relying on the Kelvinator of India case, the Tribunal's decision was upheld in favor of the assessee.
The High Court addressed the issue of reopening assessment due to disallowance of depreciation and reduced returned loss. The notice was issued after the 4-year period, leading to a challenge. The ITAT deemed the reopening as a change of opinion, thus invalid. The Court found that the assessing officer lacked tangible evidence for the reassessment and that the assessee had disclosed all necessary facts. Relying on the Kelvinator of India case, the Tribunal's decision was upheld in favor of the assessee.
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