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 an ex-parte revisionary order passed by the Principal Commissioner of Income Tax (PCIT) u/s 263 of the Income Tax Act. The key points are: The PCIT passed the revisionary order after considering the assessee's submissions, refuting allegations of violating principles of natural justice. The order was within the statutory time limit of two years from the end of the relevant financial year. The PCIT had revisionary jurisdiction as the Assessing Officer's (AO) order was erroneous and prejudicial to revenue interests by not examining cash transactions exceeding Rs. 20,000, attracting disallowance u/s 40A(3). The AO's order was cryptic, lacking examination of issues mandated for scrutiny under CASS. The PCIT correctly pointed out the AO's mistakes in not disallowing expenses u/s 40A(3) and not initiating penalty proceedings u/ss 269SS, 269T, and 271D for cash loan repayments. The PCIT directed the AO to pass a fresh assessment order, including consequential penalties, without transgressing jurisdiction u/s 263.
Validity of an ex-parte revisionary order passed by the Principal Commissioner of Income Tax (PCIT) u/s 263 of the Income Tax Act. The key points are: The PCIT passed the revisionary order after considering the assessee's submissions, refuting allegations of violating principles of natural justice. The order was within the statutory time limit of two years from the end of the relevant financial year. The PCIT had revisionary jurisdiction as the Assessing Officer's (AO) order was erroneous and prejudicial to revenue interests by not examining cash transactions exceeding Rs. 20,000, attracting disallowance u/s 40A(3). The AO's order was cryptic, lacking examination of issues mandated for scrutiny under CASS. The PCIT correctly pointed out the AO's mistakes in not disallowing expenses u/s 40A(3) and not initiating penalty proceedings u/ss 269SS, 269T, and 271D for cash loan repayments. The PCIT directed the AO to pass a fresh assessment order, including consequential penalties, without transgressing jurisdiction u/s 263.
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