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...
HC quashed reassessment proceedings under s.147 initiated after four years. AO's reasons revealed information was derived from original assessment documents, indicating predecessor officer's incorrect assessment. Court found jurisdictional conditions under first proviso to s.147 unsatisfied. AO failed to adequately address petitioner's jurisdictional objections in rejection order, merely citing judgments without specific rebuttals. Though respondents later cited audit objections, these were not mentioned in original reasons or objection order. Court held reassessment notice under s.148 was without jurisdiction, illegal and arbitrary, as reopening must be tested solely on recorded reasons without subsequent additions.
HC quashed reassessment proceedings under s.147 initiated after four years. AO's reasons revealed information was derived from original assessment documents, indicating predecessor officer's incorrect assessment. Court found jurisdictional conditions under first proviso to s.147 unsatisfied. AO failed to adequately address petitioner's jurisdictional objections in rejection order, merely citing judgments without specific rebuttals. Though respondents later cited audit objections, these were not mentioned in original reasons or objection order. Court held reassessment notice under s.148 was without jurisdiction, illegal and arbitrary, as reopening must be tested solely on recorded reasons without subsequent additions.
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