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...
Reassessment notice u/s 148 was validly issued within the six-year time limit. The Assessing Officer (AO) recorded reasons for reopening on 19.03.2018, prior to obtaining sanction u/s 151 on 23.03.2018, and issued the notice on 27.03.2018, before the deadline of 31.03.2018. The AO followed the procedure mandated by the Income-tax Act, 1961, and the Supreme Court's decision in GKN Driveshafts (India) Ltd. case. The AO had valid reasons to believe based on information from the investigation wing about bogus entries provided by entry operators. Regarding estimation of income from bogus purchases, following the Pankaj K. Chaudhary case, the disallowance was restricted to 6% of the disputed bogus purchases, as the books of account were not rejected.
Reassessment notice u/s 148 was validly issued within the six-year time limit. The Assessing Officer (AO) recorded reasons for reopening on 19.03.2018, prior to obtaining sanction u/s 151 on 23.03.2018, and issued the notice on 27.03.2018, before the deadline of 31.03.2018. The AO followed the procedure mandated by the Income-tax Act, 1961, and the Supreme Court's decision in GKN Driveshafts (India) Ltd. case. The AO had valid reasons to believe based on information from the investigation wing about bogus entries provided by entry operators. Regarding estimation of income from bogus purchases, following the Pankaj K. Chaudhary case, the disallowance was restricted to 6% of the disputed bogus purchases, as the books of account were not rejected.
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