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 ITAT considered the condonation of a 1100-day delay in filing an appeal, noting that the delay resulted from the income tax practitioner's mistaken belief that the order was not appealable. Citing the principle that "sufficient cause" should be liberally construed to advance justice, the ITAT referred to a Supreme Court case where a 1418-day delay was condoned due to unusual circumstances and misrepresentation by the advocate. The ITAT held that the ex-parte order by the PCIT violated natural justice as the assessee was not given a fair opportunity to present their case. Consequently, the order was set aside, and the matter was remitted back to the PCIT for fresh adjudication. The appeal was treated as allowed for statistical purposes.
The ITAT considered the condonation of a 1100-day delay in filing an appeal, noting that the delay resulted from the income tax practitioner's mistaken belief that the order was not appealable. Citing the principle that "sufficient cause" should be liberally construed to advance justice, the ITAT referred to a Supreme Court case where a 1418-day delay was condoned due to unusual circumstances and misrepresentation by the advocate. The ITAT held that the ex-parte order by the PCIT violated natural justice as the assessee was not given a fair opportunity to present their case. Consequently, the order was set aside, and the matter was remitted back to the PCIT for fresh adjudication. The appeal was treated as allowed for statistical purposes.
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