Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Denial of exemption u/s 10(23C)(iiiad), addition of unexplained cash credits u/s 69A. Registration granted u/s 12AA from 23-02-2019 indicating trust not exclusively engaged in education. Assessing Officer treated trust as Association of Persons, rendering income from cash deposits taxable due to lack of registration u/s 12A. Assessee's contention regarding cash deposits relating to hostel receipts from third parties not substantiated by documentary evidence or formal agreement. Income from cash deposits to be considered in hands of trust in absence of supporting documentation. Commissioner of Income Tax (Appeals) directed to re-examine classification as Association of Persons and tax implications, ensuring income without third-party attribution is taxed in hands of trust. Order of Commissioner of Income Tax (Appeals) set aside, matter remitted for fresh adjudication as per law after considering facts, evidence, and submissions. Appeal allowed for statistical purposes.
Denial of exemption u/s 10(23C)(iiiad), addition of unexplained cash credits u/s 69A. Registration granted u/s 12AA from 23-02-2019 indicating trust not exclusively engaged in education. Assessing Officer treated trust as Association of Persons, rendering income from cash deposits taxable due to lack of registration u/s 12A. Assessee's contention regarding cash deposits relating to hostel receipts from third parties not substantiated by documentary evidence or formal agreement. Income from cash deposits to be considered in hands of trust in absence of supporting documentation. Commissioner of Income Tax (Appeals) directed to re-examine classification as Association of Persons and tax implications, ensuring income without third-party attribution is taxed in hands of trust. Order of Commissioner of Income Tax (Appeals) set aside, matter remitted for fresh adjudication as per law after considering facts, evidence, and submissions. Appeal allowed for statistical purposes.
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