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 under s.147 for AY 2014-15 initiated beyond four years. AO failed to demonstrate any failure by assessee to fully disclose material facts necessary for assessment. Reopening was based on existing records already furnished during original assessment. No fresh tangible material existed to form independent opinion for reopening. Mandatory procedures under s.144B were violated as objections to reopening notice were not addressed. AO passed final order within one day of receiving assessee's reply to draft assessment order without providing reasonable opportunity of hearing. Order declared void for violating natural justice principles and jurisdictional requirements under first proviso to s.147.
HC invalidated reassessment proceedings under s.147 for AY 2014-15 initiated beyond four years. AO failed to demonstrate any failure by assessee to fully disclose material facts necessary for assessment. Reopening was based on existing records already furnished during original assessment. No fresh tangible material existed to form independent opinion for reopening. Mandatory procedures under s.144B were violated as objections to reopening notice were not addressed. AO passed final order within one day of receiving assessee's reply to draft assessment order without providing reasonable opportunity of hearing. Order declared void for violating natural justice principles and jurisdictional requirements under first proviso to s.147.
Note: It is a system-generated summary and is for quick reference only.