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 reopening assessment u/s 147 challenged. Profit earned by trading in shares treated as unexplained credit u/s 68. Held: Petitioner disclosed all material facts including derivatives transactions in books during regular assessment proceedings. Assessing Officer passed order u/s 143(3) assessing total income. Despite profit from transactions being offered to tax in return, reopening initiated based on information received. However, Assessing Officer failed to correlate information with records and material already scrutinized during regular assessment. Petitioner provided all information, disclosing material facts fully. Reopening notice without jurisdiction, contrary to provisions, as no fresh tangible material for reasonable belief of escaped income. Mere change of opinion on profit already offered to tax. Decided in favor of assessee. Impugned notice quashed and set aside.
Validity of reopening assessment u/s 147 challenged. Profit earned by trading in shares treated as unexplained credit u/s 68. Held: Petitioner disclosed all material facts including derivatives transactions in books during regular assessment proceedings. Assessing Officer passed order u/s 143(3) assessing total income. Despite profit from transactions being offered to tax in return, reopening initiated based on information received. However, Assessing Officer failed to correlate information with records and material already scrutinized during regular assessment. Petitioner provided all information, disclosing material facts fully. Reopening notice without jurisdiction, contrary to provisions, as no fresh tangible material for reasonable belief of escaped income. Mere change of opinion on profit already offered to tax. Decided in favor of assessee. Impugned notice quashed and set aside.
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