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...
Revision u/s 263 regarding claim of accommodation entry - reliance on statements of third parties. Timelines for completing assessment u/s 143(3). Assessing officer duly inquired into claim of accommodation entry during Section 147 proceedings. Principal Commissioner of Income Tax (PCIT) did not provide specific findings on how assessment order was erroneous and prejudicial to revenue's interest. PCIT resorted to Section 263 proceedings to extend timelines for framing assessment u/s 147, which is impermissible. PCIT should have conducted necessary inquiries or verification to show Assessing Officer's findings were unsustainable. PCIT failed to provide independent finding on how assessment order was legally unsustainable based on available information. Assessee submitted no long-term capital gains earned during the year, only short-term capital gains on which taxes were paid. Assessee's appeal allowed by Income Tax Appellate Tribunal (ITAT).
Revision u/s 263 regarding claim of accommodation entry - reliance on statements of third parties. Timelines for completing assessment u/s 143(3). Assessing officer duly inquired into claim of accommodation entry during Section 147 proceedings. Principal Commissioner of Income Tax (PCIT) did not provide specific findings on how assessment order was erroneous and prejudicial to revenue's interest. PCIT resorted to Section 263 proceedings to extend timelines for framing assessment u/s 147, which is impermissible. PCIT should have conducted necessary inquiries or verification to show Assessing Officer's findings were unsustainable. PCIT failed to provide independent finding on how assessment order was legally unsustainable based on available information. Assessee submitted no long-term capital gains earned during the year, only short-term capital gains on which taxes were paid. Assessee's appeal allowed by Income Tax Appellate Tribunal (ITAT).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
