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...
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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...
Merely deriving information through faceless scheme u/s 135A cannot create arbitrary consequences. Safeguards are needed to prevent defective information leading to Section 148 notice. Not all information u/s 135A is sacrosanct or defect-free. Once defect is pointed out, AO must consider assessee's version before issuing Section 148 notice. AO failed to verify correctness of electronic information with assessee's explanation before issuing impugned Section 148 notice. AO needs to apply mind, verify materials, and form opinion before dispensing with Section 148A procedure for Section 148 notice based on Section 135A information. Impugned Section 148 notice quashed for non-application of mind and being arbitrary.
Merely deriving information through faceless scheme u/s 135A cannot create arbitrary consequences. Safeguards are needed to prevent defective information leading to Section 148 notice. Not all information u/s 135A is sacrosanct or defect-free. Once defect is pointed out, AO must consider assessee's version before issuing Section 148 notice. AO failed to verify correctness of electronic information with assessee's explanation before issuing impugned Section 148 notice. AO needs to apply mind, verify materials, and form opinion before dispensing with Section 148A procedure for Section 148 notice based on Section 135A information. Impugned Section 148 notice quashed for non-application of mind and being arbitrary.
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