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 reassessment notice issued under Section 148 for AY 2013-14, ruling that the basic requirement of "failure to disclose" was not satisfied. The assessee had disclosed expenditure towards bad debts written off in the profit and loss account, though it was also shown as provisions in the trial balance. The AO had originally considered this very ground while passing the assessment order dated 24.2.2016. The court held that the reopening notice was based on mere change of opinion, which does not constitute valid reason to believe that income chargeable to tax has escaped assessment. The petition was decided in favour of the assessee, establishing that disclosed information cannot form basis for reassessment proceedings.
The HC quashed the reassessment notice issued under Section 148 for AY 2013-14, ruling that the basic requirement of "failure to disclose" was not satisfied. The assessee had disclosed expenditure towards bad debts written off in the profit and loss account, though it was also shown as provisions in the trial balance. The AO had originally considered this very ground while passing the assessment order dated 24.2.2016. The court held that the reopening notice was based on mere change of opinion, which does not constitute valid reason to believe that income chargeable to tax has escaped assessment. The petition was decided in favour of the assessee, establishing that disclosed information cannot form basis for reassessment proceedings.
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