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...
CIT(A) erred in directing reassessment under Section 194C after High Court quashed original assessment order under Section 194I. While CIT(A) holds powers coextensive with AO under Section 251 including enhancement and reduction of assessment, these powers can only be exercised when there exists a valid, enforceable order under appeal. Once HC quashed the underlying AO order regarding TDS on External Development Charges, CIT(A) lacked jurisdiction to direct recomputation under different provisions. The attempted change from Section 194I to Section 194C assessment was invalid absent an existing enforceable order. ITAT allowed assessee's appeal, holding CIT(A)'s direction for demand recomputation legally untenable.
CIT(A) erred in directing reassessment under Section 194C after High Court quashed original assessment order under Section 194I. While CIT(A) holds powers coextensive with AO under Section 251 including enhancement and reduction of assessment, these powers can only be exercised when there exists a valid, enforceable order under appeal. Once HC quashed the underlying AO order regarding TDS on External Development Charges, CIT(A) lacked jurisdiction to direct recomputation under different provisions. The attempted change from Section 194I to Section 194C assessment was invalid absent an existing enforceable order. ITAT allowed assessee's appeal, holding CIT(A)'s direction for demand recomputation legally untenable.
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