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...
Undisclosed income surrendered during search must fall within the definition of undisclosed income for penalty u/s 271AAA to be justified. Assessing Officer must record specific finding that undisclosed income was found based on verifiable material during search. Mere surrender to cover potential discrepancy doesn't satisfy definition of undisclosed income. Onus is on Assessing Officer, not assessee, to establish conditions for penalty levy are met. CIT(A) rightly held no discrepancy pointed out, hence surrender doesn't qualify as undisclosed income, but erred in confirming penalty. Penalty u/s 271AAA deleted as no legal basis established.
Undisclosed income surrendered during search must fall within the definition of undisclosed income for penalty u/s 271AAA to be justified. Assessing Officer must record specific finding that undisclosed income was found based on verifiable material during search. Mere surrender to cover potential discrepancy doesn't satisfy definition of undisclosed income. Onus is on Assessing Officer, not assessee, to establish conditions for penalty levy are met. CIT(A) rightly held no discrepancy pointed out, hence surrender doesn't qualify as undisclosed income, but erred in confirming penalty. Penalty u/s 271AAA deleted as no legal basis established.
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