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...
Reopening of assessment - Addition u/s 68 - unsecured loans treated as bogus - reassessment merely based on information from investigation wing held unjustified. Powers of assessing officer to reopen wide but not plenary - "reason to believe" required, not mere "reason to suspect". Belief must be of honest, reasonable person based on reasonable grounds, not suspicion or rumour. Assessing officer acted without jurisdiction if reason for belief of escaped income non-existent or irrelevant. Assessee furnished sufficient documents proving identity, creditworthiness of creditors, genuineness of transactions. Creditor's assessment order accepted creditworthiness. Hence, addition u/s 68 unwarranted.
Reopening of assessment - Addition u/s 68 - unsecured loans treated as bogus - reassessment merely based on information from investigation wing held unjustified. Powers of assessing officer to reopen wide but not plenary - "reason to believe" required, not mere "reason to suspect". Belief must be of honest, reasonable person based on reasonable grounds, not suspicion or rumour. Assessing officer acted without jurisdiction if reason for belief of escaped income non-existent or irrelevant. Assessee furnished sufficient documents proving identity, creditworthiness of creditors, genuineness of transactions. Creditor's assessment order accepted creditworthiness. Hence, addition u/s 68 unwarranted.
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