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 ITAT held that the Black Money Act, 2015 would be applicable from AY 2016-17 onwards. Hence, the AO lacked jurisdiction to assess income or levy penalty under the Act for AYs 2014-15 and 2015-16. Regarding AY 2016-17, the dividend income reinvested in the Non-Retirement Fund (NRF) did not constitute undisclosed foreign income/asset as the tax was withheld as per USA laws. The penalty u/s 41 was deleted consequentially. The penalty u/s 43 was also rightly deleted by the CIT(A) considering it was the first year of the Act's implementation, the assets were from known sources with taxes paid, and the lapse was unintentional. The revenue's appeals were dismissed.
The ITAT held that the Black Money Act, 2015 would be applicable from AY 2016-17 onwards. Hence, the AO lacked jurisdiction to assess income or levy penalty under the Act for AYs 2014-15 and 2015-16. Regarding AY 2016-17, the dividend income reinvested in the Non-Retirement Fund (NRF) did not constitute undisclosed foreign income/asset as the tax was withheld as per USA laws. The penalty u/s 41 was deleted consequentially. The penalty u/s 43 was also rightly deleted by the CIT(A) considering it was the first year of the Act's implementation, the assets were from known sources with taxes paid, and the lapse was unintentional. The revenue's appeals were dismissed.
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