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...
ITAT quashed reassessment proceedings regarding alleged undisclosed "on-money" payments to builder for residential property. AO's reliance on pen drive and documents seized during third-party search operation deemed insufficient without corroborative evidence. Assessee consistently denied making cash payments above agreement value. Critical procedural deficiencies noted: seized materials not confronted with assessee, statements under s.131 not shared, and no explicit mention of assessee in seized documents. ITAT emphasized that uncorroborated digital evidence from third-party searches cannot constitute credible basis for reassessment. Violation of natural justice principles where adverse materials not provided to assessee. Addition deleted as AO failed to establish authenticity of digital evidence or verify reliability of pen drive data.
ITAT quashed reassessment proceedings regarding alleged undisclosed "on-money" payments to builder for residential property. AO's reliance on pen drive and documents seized during third-party search operation deemed insufficient without corroborative evidence. Assessee consistently denied making cash payments above agreement value. Critical procedural deficiencies noted: seized materials not confronted with assessee, statements under s.131 not shared, and no explicit mention of assessee in seized documents. ITAT emphasized that uncorroborated digital evidence from third-party searches cannot constitute credible basis for reassessment. Violation of natural justice principles where adverse materials not provided to assessee. Addition deleted as AO failed to establish authenticity of digital evidence or verify reliability of pen drive data.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
