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 ruled on validity of assessment under Section 153C, clarifying that discovery of documents pertaining to third parties during search operations triggers jurisdiction, regardless of relationship between searched and non-searched entities. The provision's applicability depends solely on finding incriminating material likely to impact non-searched entity's income assessment. Court rejected argument requiring connection between searched and non-searched parties, emphasizing that Section 153C specifically addresses materials belonging to unrelated third parties. Assessing Officer's obligation extends only to evaluating if discovered materials affect total income determination of non-searched entity. Reading requirement of relationship between parties would contradict statutory purpose. Writ petition dismissed, upholding validity of Section 153C proceedings.
HC ruled on validity of assessment under Section 153C, clarifying that discovery of documents pertaining to third parties during search operations triggers jurisdiction, regardless of relationship between searched and non-searched entities. The provision's applicability depends solely on finding incriminating material likely to impact non-searched entity's income assessment. Court rejected argument requiring connection between searched and non-searched parties, emphasizing that Section 153C specifically addresses materials belonging to unrelated third parties. Assessing Officer's obligation extends only to evaluating if discovered materials affect total income determination of non-searched entity. Reading requirement of relationship between parties would contradict statutory purpose. Writ petition dismissed, upholding validity of Section 153C proceedings.
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