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...
Digital images and Excel files found on partner's phone cannot be relied upon for making additions u/s 69C for unexplained expenditure. Loose papers and documents not corroborated by other evidence are considered dumb documents inadmissible as evidence. Mere entries in seized documents without proof of actual transactions cannot justify additions. Presumptions of imports based solely on electronic files without supporting materials are invalid. Additions made by the Assessing Officer solely relying on such uncorroborated electronic data were rightly deleted by the Tribunal following judicial precedents.
Digital images and Excel files found on partner's phone cannot be relied upon for making additions u/s 69C for unexplained expenditure. Loose papers and documents not corroborated by other evidence are considered dumb documents inadmissible as evidence. Mere entries in seized documents without proof of actual transactions cannot justify additions. Presumptions of imports based solely on electronic files without supporting materials are invalid. Additions made by the Assessing Officer solely relying on such uncorroborated electronic data were rightly deleted by the Tribunal following judicial precedents.
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