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 upholds validity of the assessment proceedings: the notice under s.143(2) and accompanying questionnaire were issued after application of mind and are not mechanical; therefore grounds challenging re-assessment notice and service are dismissed. Procedural fairness is affirmed - multiple opportunities to be heard were afforded and no infirmity found. The contention regarding non-acknowledgement of ITR-V was rejected under the principle in s.292B for participating in proceedings without contemporaneous objection. Non-supply of reasons recorded was not fatal where no formal request was made. Substantive relief granted: long-term capital gains from sale of ancestral land must be assessed in HUF capacity, not in the individual's hands. Addition treating declared agricultural income as undisclosed is upheld.
ITAT upholds validity of the assessment proceedings: the notice under s.143(2) and accompanying questionnaire were issued after application of mind and are not mechanical; therefore grounds challenging re-assessment notice and service are dismissed. Procedural fairness is affirmed - multiple opportunities to be heard were afforded and no infirmity found. The contention regarding non-acknowledgement of ITR-V was rejected under the principle in s.292B for participating in proceedings without contemporaneous objection. Non-supply of reasons recorded was not fatal where no formal request was made. Substantive relief granted: long-term capital gains from sale of ancestral land must be assessed in HUF capacity, not in the individual's hands. Addition treating declared agricultural income as undisclosed is upheld.
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