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 set aside the impugned appellate order and remanded the matter to the AO for fresh quantification of the addition, directing recomputation in accordance with law after affording the assessee a reasonable opportunity to be heard. Tribunal held that, although approval under s.10(23C) existed, the assessee consciously elected to claim exemption under s.11 read with s.12A in the assessment proceedings and therefore CIT(A) erred in granting benefit under s.10(23C) which was not pleaded before the AO. The question of quantum of addition (previously disputed between specified amounts) is restored to the file of the AO for verification and determination consistent with this decision.
ITAT set aside the impugned appellate order and remanded the matter to the AO for fresh quantification of the addition, directing recomputation in accordance with law after affording the assessee a reasonable opportunity to be heard. Tribunal held that, although approval under s.10(23C) existed, the assessee consciously elected to claim exemption under s.11 read with s.12A in the assessment proceedings and therefore CIT(A) erred in granting benefit under s.10(23C) which was not pleaded before the AO. The question of quantum of addition (previously disputed between specified amounts) is restored to the file of the AO for verification and determination consistent with this decision.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
