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...
Addition made u/s 153A on account of undisclosed foreign bank account and interest income thereon - assessee confronted with client profiles from HSBC Bank showing unique code assigned for operation of foreign bank account - Revenue possessed overwhelming material indicating assessee held foreign bank account which assessee refused to confirm by not providing consent waiver form citing self-incrimination plea rejected as not maintainable - adverse inference drawn from assessee's conduct and undertaking - addition of imputed interest income not sustainable as bank account closed before relevant period. Addition on unexplained investment in jewelry - part addition deleted for jewelry received as wedding gifts with supporting evidence, balance addition confirmed for lack of proper details regarding jewelry claimed as received on children's birthdays.
Addition made u/s 153A on account of undisclosed foreign bank account and interest income thereon - assessee confronted with client profiles from HSBC Bank showing unique code assigned for operation of foreign bank account - Revenue possessed overwhelming material indicating assessee held foreign bank account which assessee refused to confirm by not providing consent waiver form citing self-incrimination plea rejected as not maintainable - adverse inference drawn from assessee's conduct and undertaking - addition of imputed interest income not sustainable as bank account closed before relevant period. Addition on unexplained investment in jewelry - part addition deleted for jewelry received as wedding gifts with supporting evidence, balance addition confirmed for lack of proper details regarding jewelry claimed as received on children's birthdays.
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