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...
The HC quashed an undated assessment order under s.143(3) of the Income Tax Act, finding multiple legal deficiencies. The AO improperly abdicated discretionary authority by consulting with superior officers who actively participated in drafting the assessment order rather than merely approving it as required by CBDT Circular. The court determined that principles of natural justice were violated as the petitioner was not afforded reasonable opportunity to present a defense. Additionally, the assessment order was deemed time-barred, as evidence showed it was not actually made by March 31, 2024, despite revenue authorities' claims. The HC rejected the revenue's "flimsy attempt" to retroactively establish timely issuance, declaring the order non est and legally unsustainable.
The HC quashed an undated assessment order under s.143(3) of the Income Tax Act, finding multiple legal deficiencies. The AO improperly abdicated discretionary authority by consulting with superior officers who actively participated in drafting the assessment order rather than merely approving it as required by CBDT Circular. The court determined that principles of natural justice were violated as the petitioner was not afforded reasonable opportunity to present a defense. Additionally, the assessment order was deemed time-barred, as evidence showed it was not actually made by March 31, 2024, despite revenue authorities' claims. The HC rejected the revenue's "flimsy attempt" to retroactively establish timely issuance, declaring the order non est and legally unsustainable.
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