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...
AO's jurisdiction was challenged regarding notice u/s 143(2) after territorial reassignment. ITAT determined that jurisdictional challenges fall under Part B, Chapter XIII, requiring administrative consideration first. Neither ITO nor ACIT lacked territorial jurisdiction; the change merely reflected pecuniary jurisdiction under s.120(3). Following precedents from Kalinga Institute and Mantoo Sarkar cases, ITAT ruled pecuniary jurisdiction challenge as untimely and curable. Regarding sundry creditors, CIT(A)'s enhancement under s.41(1) was found procedurally flawed. Matter remanded to AO for determining creditors' genuineness and appropriate year-wise additions, subject to statutory limitations. Assessee directed to furnish complete documentation for accurate assessment.
AO's jurisdiction was challenged regarding notice u/s 143(2) after territorial reassignment. ITAT determined that jurisdictional challenges fall under Part B, Chapter XIII, requiring administrative consideration first. Neither ITO nor ACIT lacked territorial jurisdiction; the change merely reflected pecuniary jurisdiction under s.120(3). Following precedents from Kalinga Institute and Mantoo Sarkar cases, ITAT ruled pecuniary jurisdiction challenge as untimely and curable. Regarding sundry creditors, CIT(A)'s enhancement under s.41(1) was found procedurally flawed. Matter remanded to AO for determining creditors' genuineness and appropriate year-wise additions, subject to statutory limitations. Assessee directed to furnish complete documentation for accurate assessment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
