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 u/s 147 - Validity of approval u/s 151 - notice not issued by Faceless Assessing Officer (FAO) - There is no concurrent jurisdiction for Joint Assessing Officer (JAO) and FAO for issuing notice u/s 148 or passing assessment/reassessment order. When specific jurisdiction assigned to FAO under Scheme dated 29 March 2022 notified u/s 151A, it excludes JAO's jurisdiction. Section 151A contemplates formulation of Scheme for assessment/reassessment u/s 147 and issuance of notice u/s 148. Scheme covers both aspects. Only FAO can issue notice u/s 148, not JAO. Impugned notice issued by JAO hit by Section 151A for lack of jurisdiction. Impugned notice u/s 148 quashed and set aside as barred by limitation and contrary to Section 151A.
Reopening of assessment u/s 147 - Validity of approval u/s 151 - notice not issued by Faceless Assessing Officer (FAO) - There is no concurrent jurisdiction for Joint Assessing Officer (JAO) and FAO for issuing notice u/s 148 or passing assessment/reassessment order. When specific jurisdiction assigned to FAO under Scheme dated 29 March 2022 notified u/s 151A, it excludes JAO's jurisdiction. Section 151A contemplates formulation of Scheme for assessment/reassessment u/s 147 and issuance of notice u/s 148. Scheme covers both aspects. Only FAO can issue notice u/s 148, not JAO. Impugned notice issued by JAO hit by Section 151A for lack of jurisdiction. Impugned notice u/s 148 quashed and set aside as barred by limitation and contrary to Section 151A.
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