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 revision u/s 263 - subsequent revision orders - first order set aside by PCIT - ITAT quashing revisionary proceedings - adoption of accrual basis of accounting - assessee company followed mercantile system and showed trade receivables - assessee bound to adhere to Ministry of Power's direction to account for interest on cash basis - order u/s 263 invalid once first order quashed - no subsequent order permissible - res judicata principle applicable - Tribunal's order justified in absence of challenge to fundamental aspect across assessment years.
Validity of revision u/s 263 - subsequent revision orders - first order set aside by PCIT - ITAT quashing revisionary proceedings - adoption of accrual basis of accounting - assessee company followed mercantile system and showed trade receivables - assessee bound to adhere to Ministry of Power's direction to account for interest on cash basis - order u/s 263 invalid once first order quashed - no subsequent order permissible - res judicata principle applicable - Tribunal's order justified in absence of challenge to fundamental aspect across assessment years.
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