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...
Validity of order passed u/ss 154/147/143(3) - Disallowance of prior period expenses - Relevant previous year being first year of assessee's business, no prior period expenses existed - Quantum addition and charging of interest in reassessment order u/s 147/143 cannot be raised during appellate proceedings initiated due to revision/rectification order u/s 154/147/143(3) - Rectification order cannot challenge validity and quantum addition made in reassessment order - Appeal challenging quantum addition dismissed.
Validity of order passed u/ss 154/147/143(3) - Disallowance of prior period expenses - Relevant previous year being first year of assessee's business, no prior period expenses existed - Quantum addition and charging of interest in reassessment order u/s 147/143 cannot be raised during appellate proceedings initiated due to revision/rectification order u/s 154/147/143(3) - Rectification order cannot challenge validity and quantum addition made in reassessment order - Appeal challenging quantum addition dismissed.
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