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...
ITAT held revisionary powers under s.263 cannot be invoked as assessment order was neither erroneous nor prejudicial to Revenue's interests. During survey, assessee surrendered undisclosed income which was included in tax returns. AO conducted specific inquiry regarding applicability of s.115BBE through show cause notice. PCIT cannot merely substitute their view that income should be treated as unexplained investment under s.69 (Rs.66,50,000) and unexplained money under s.69A (Rs.9,50,000). Amendment via Explanation 2(a) expanding revisionary powers does not grant unlimited authority. No errors of law or fact were found in AO's order, which represented a plausible interpretation after proper inquiry. Appeal decided in assessee's favor.
ITAT held revisionary powers under s.263 cannot be invoked as assessment order was neither erroneous nor prejudicial to Revenue's interests. During survey, assessee surrendered undisclosed income which was included in tax returns. AO conducted specific inquiry regarding applicability of s.115BBE through show cause notice. PCIT cannot merely substitute their view that income should be treated as unexplained investment under s.69 (Rs.66,50,000) and unexplained money under s.69A (Rs.9,50,000). Amendment via Explanation 2(a) expanding revisionary powers does not grant unlimited authority. No errors of law or fact were found in AO's order, which represented a plausible interpretation after proper inquiry. Appeal decided in assessee's favor.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
