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 quashed reassessment notice issued under section 14A read with Rule 8D for disallowance of expenditure relating to exempt income. Petitioner-company had originally provided complete details regarding exempt income and investments during regular assessment proceedings, with no disallowance made. AO's reopening was based solely on verification of profit and loss account and balance sheet without any fresh tangible material. Court held that reassessment cannot be initiated on mere change of opinion regarding same set of facts previously considered. Respondent failed to address petitioner's objection regarding delayed reply beyond sixty-day period. Reassessment proceedings constitute impermissible review of original assessment order passed under section 143(3). Petition allowed in favor of assessee.
HC quashed reassessment notice issued under section 14A read with Rule 8D for disallowance of expenditure relating to exempt income. Petitioner-company had originally provided complete details regarding exempt income and investments during regular assessment proceedings, with no disallowance made. AO's reopening was based solely on verification of profit and loss account and balance sheet without any fresh tangible material. Court held that reassessment cannot be initiated on mere change of opinion regarding same set of facts previously considered. Respondent failed to address petitioner's objection regarding delayed reply beyond sixty-day period. Reassessment proceedings constitute impermissible review of original assessment order passed under section 143(3). Petition allowed in favor of assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
