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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...
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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...
Distinction between "lack of inquiry and inadequate inquiry" emphasized. Assessee underwent rigorous assessment proceedings with multiple notices and replies. AO accepted returned income after due diligence, proper inquiry, and verification. Raising queries and examining records shows AO's application of mind. Entire record examined before concluding AO didn't examine any issue. Enquiry methodology prescribed followed. AO framed assessment considering assessee's replies. PCIT didn't conduct bare minimum inquiry before terming AO's order erroneous and prejudicial. Impugned PCIT order without jurisdiction, in excess of jurisdiction, irregular exercise of jurisdiction, null, void, illegal, improper exercise of revisionary jurisdiction u/s 263. Decided in assessee's favor.
Distinction between "lack of inquiry and inadequate inquiry" emphasized. Assessee underwent rigorous assessment proceedings with multiple notices and replies. AO accepted returned income after due diligence, proper inquiry, and verification. Raising queries and examining records shows AO's application of mind. Entire record examined before concluding AO didn't examine any issue. Enquiry methodology prescribed followed. AO framed assessment considering assessee's replies. PCIT didn't conduct bare minimum inquiry before terming AO's order erroneous and prejudicial. Impugned PCIT order without jurisdiction, in excess of jurisdiction, irregular exercise of jurisdiction, null, void, illegal, improper exercise of revisionary jurisdiction u/s 263. Decided in assessee's favor.
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