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 the Best Judgment Assessment order under section 144, finding it legally untenable as the Assessing Officer failed to properly consider the petitioner's voluminous reply to the show cause notice. While the AO claimed to have found the reply unsatisfactory, no reasons were provided for this conclusion. Following Supreme Court precedent in M/S SHUKLA & BROTHERS, the matter was remanded for a fresh de novo assessment. The AO must provide the petitioner with a hearing opportunity if requested, consider their submissions, and issue a reasoned order within 12 weeks of receiving the court's decision.
The HC quashed the Best Judgment Assessment order under section 144, finding it legally untenable as the Assessing Officer failed to properly consider the petitioner's voluminous reply to the show cause notice. While the AO claimed to have found the reply unsatisfactory, no reasons were provided for this conclusion. Following Supreme Court precedent in M/S SHUKLA & BROTHERS, the matter was remanded for a fresh de novo assessment. The AO must provide the petitioner with a hearing opportunity if requested, consider their submissions, and issue a reasoned order within 12 weeks of receiving the court's decision.
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