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 invalidated reassessment proceedings initiated under s148A(b) based on alleged bogus capital expenses identified through CRIU/VRU information. Revenue's physical verification and subsequent order under s148A(d) violated natural justice principles as assessee was not given opportunity to respond to allegations regarding non-existent entity. Court emphasized that post original assessment closure, AO becomes functus officio and jurisdiction for reassessment requires proper disclosure of incriminating material to assessee. Physical verification findings about entity's non-existence at Jasola address were not communicated via show cause notice, making the reassessment proceedings procedurally defective. Order set aside in assessee's favor.
HC invalidated reassessment proceedings initiated under s148A(b) based on alleged bogus capital expenses identified through CRIU/VRU information. Revenue's physical verification and subsequent order under s148A(d) violated natural justice principles as assessee was not given opportunity to respond to allegations regarding non-existent entity. Court emphasized that post original assessment closure, AO becomes functus officio and jurisdiction for reassessment requires proper disclosure of incriminating material to assessee. Physical verification findings about entity's non-existence at Jasola address were not communicated via show cause notice, making the reassessment proceedings procedurally defective. Order set aside in assessee's favor.
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