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 challenged for lack of proper inquiry by Assessing Officer regarding cash deposits during demonetization, scrap sales, and non-submission of audit report. ITAT set aside revision order. Substantial question of law raised. Held that department only challenged factual findings of Tribunal. Supreme Court precedents establish that no substantial question of law arises from factual findings unless perverse. Perversity defined as finding without evidence, unreasonable, based on surmises or suspicion. Tribunal's factual finding perverse only if affecting substantial rights of assessee unreasonably based on record. Tribunal examined facts in detail before ruling in assessee's favor. No perversity found in Tribunal's fact finding.
Revision u/s 263 challenged for lack of proper inquiry by Assessing Officer regarding cash deposits during demonetization, scrap sales, and non-submission of audit report. ITAT set aside revision order. Substantial question of law raised. Held that department only challenged factual findings of Tribunal. Supreme Court precedents establish that no substantial question of law arises from factual findings unless perverse. Perversity defined as finding without evidence, unreasonable, based on surmises or suspicion. Tribunal's factual finding perverse only if affecting substantial rights of assessee unreasonably based on record. Tribunal examined facts in detail before ruling in assessee's favor. No perversity found in Tribunal's fact finding.
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