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...
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Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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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 ITAT addressed reassessment proceedings under Section 148, finding the Assessing Officer's (AO) reasons to believe were valid based on information from the DIT(System). The tribunal rejected the assessee's argument of mere "change of opinion" and upheld the approval under Section 151 as independent and substantive. Regarding share transfer, the ITAT ruled against the AO's "look through approach" and invalidated the recharacterization of share sale as asset sale. The tribunal specifically held that Section 50CA could not be retrospectively applied for Assessment Year 2015-16, directing deletion of short-term capital gains additions. The appeal grounds relating to reassessment and valuation were partially allowed, with grounds 3-7 dismissed and grounds 12-18 allowed.
The ITAT addressed reassessment proceedings under Section 148, finding the Assessing Officer's (AO) reasons to believe were valid based on information from the DIT(System). The tribunal rejected the assessee's argument of mere "change of opinion" and upheld the approval under Section 151 as independent and substantive. Regarding share transfer, the ITAT ruled against the AO's "look through approach" and invalidated the recharacterization of share sale as asset sale. The tribunal specifically held that Section 50CA could not be retrospectively applied for Assessment Year 2015-16, directing deletion of short-term capital gains additions. The appeal grounds relating to reassessment and valuation were partially allowed, with grounds 3-7 dismissed and grounds 12-18 allowed.
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