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 ITAT set aside the orders of the Assessing Officer and the First Appellate Authority regarding the demand under section 201(1)/201(1A) for non-deduction of TDS on LTC/LFC reimbursements, citing non-compliance with principles of natural justice due to the assessee's non-receipt of hearing notices. The matter was remanded to the AO for fresh adjudication, directing the assessee to file necessary evidence. Regarding the penalty under section 271C, the tribunal also set aside the impugned penalty order for reconsideration, as the assessee's submissions were not previously considered. Both appeals were allowed for statistical purposes, emphasizing the requirement of fair opportunity for the assessee to present its case before finalizing any demand or penalty.
The ITAT set aside the orders of the Assessing Officer and the First Appellate Authority regarding the demand under section 201(1)/201(1A) for non-deduction of TDS on LTC/LFC reimbursements, citing non-compliance with principles of natural justice due to the assessee's non-receipt of hearing notices. The matter was remanded to the AO for fresh adjudication, directing the assessee to file necessary evidence. Regarding the penalty under section 271C, the tribunal also set aside the impugned penalty order for reconsideration, as the assessee's submissions were not previously considered. Both appeals were allowed for statistical purposes, emphasizing the requirement of fair opportunity for the assessee to present its case before finalizing any demand or penalty.
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