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 held that reassessment proceedings for AY 2002-03 and 2003-04 were invalid as they were initiated beyond the four-year limitation period. The revenue failed to establish that the assessee intentionally suppressed material information. The error in the commencement date was considered inadvertent, not deliberate. For AY 2004-05, the reassessment was within the four-year period, but no material justification was found to reopen the original assessment. The court emphasized that reassessment is not a review process and must be based on tangible evidence of non-disclosure. Consequently, the writ appeal was dismissed, protecting the assessee's original tax assessments.
HC held that reassessment proceedings for AY 2002-03 and 2003-04 were invalid as they were initiated beyond the four-year limitation period. The revenue failed to establish that the assessee intentionally suppressed material information. The error in the commencement date was considered inadvertent, not deliberate. For AY 2004-05, the reassessment was within the four-year period, but no material justification was found to reopen the original assessment. The court emphasized that reassessment is not a review process and must be based on tangible evidence of non-disclosure. Consequently, the writ appeal was dismissed, protecting the assessee's original tax assessments.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
