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 addressed multiple taxation issues involving unexplained income and profit calculations. The tribunal found that when entire contract receipts were treated as unexplained, no further profit addition was justified. The CIT(A)'s order was set aside due to procedural irregularities in admitting additional evidence without providing the AO an opportunity to examine such evidence, as mandated under Rule 46A(3) of IT Rules. The tribunal upheld the 10% profit rate calculation, noting it was more reasonable than the AO's unsubstantiated 20% rate. The matter was remanded to the first appellate authority for reconsideration, ensuring procedural compliance and fair assessment of the taxpayer's income.
ITAT addressed multiple taxation issues involving unexplained income and profit calculations. The tribunal found that when entire contract receipts were treated as unexplained, no further profit addition was justified. The CIT(A)'s order was set aside due to procedural irregularities in admitting additional evidence without providing the AO an opportunity to examine such evidence, as mandated under Rule 46A(3) of IT Rules. The tribunal upheld the 10% profit rate calculation, noting it was more reasonable than the AO's unsubstantiated 20% rate. The matter was remanded to the first appellate authority for reconsideration, ensuring procedural compliance and fair assessment of the taxpayer's income.
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