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 held that the reassessment order is void ab initio and quashed it in toto. The Tribunal found the impugned order unsigned, rendering it legally ineffective; proceedings were instituted and concluded against a struck-off/defunct company that had ceased to exist; and the addition related to an assessment year unconnected to the subject transaction. These defects, individually sufficient to vitiate the assessment, cumulatively established that the reassessment was a legal nullity. The erstwhile director's age and health-related difficulties in assembling records did not justify sustaining proceedings fundamentally flawed in form and jurisdiction. Consequentially, the reassessment and resultant additions were set aside.
The ITAT held that the reassessment order is void ab initio and quashed it in toto. The Tribunal found the impugned order unsigned, rendering it legally ineffective; proceedings were instituted and concluded against a struck-off/defunct company that had ceased to exist; and the addition related to an assessment year unconnected to the subject transaction. These defects, individually sufficient to vitiate the assessment, cumulatively established that the reassessment was a legal nullity. The erstwhile director's age and health-related difficulties in assembling records did not justify sustaining proceedings fundamentally flawed in form and jurisdiction. Consequentially, the reassessment and resultant additions were set aside.
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