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...
The High Court examined the validity of reopening an assessment and invoking the extended period of limitation to add deemed dividend u/s 2(22)(e) of the Income Tax Act. The assessee had purchased a property, receiving the entire amount from a company where the assessee held 29% shares. The court held that the revenue authorities sought to add a sum as "deemed income" through the reassessment order, which was unsuccessfully challenged by the assessee. However, the Tribunal reversed the Commissioner's order affirming the reassessment. The court observed that the department's attempt was to merely include an additional amount over the sum subject to the earlier assessment order, which stood deleted. Considering the appeal's withdrawal, the issue was construed as answered against the revenue and in favor of the assessee, implying a lack of tangible material for reopening the assessment.
The High Court examined the validity of reopening an assessment and invoking the extended period of limitation to add deemed dividend u/s 2(22)(e) of the Income Tax Act. The assessee had purchased a property, receiving the entire amount from a company where the assessee held 29% shares. The court held that the revenue authorities sought to add a sum as "deemed income" through the reassessment order, which was unsuccessfully challenged by the assessee. However, the Tribunal reversed the Commissioner's order affirming the reassessment. The court observed that the department's attempt was to merely include an additional amount over the sum subject to the earlier assessment order, which stood deleted. Considering the appeal's withdrawal, the issue was construed as answered against the revenue and in favor of the assessee, implying a lack of tangible material for reopening the assessment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
