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 quashed the PCIT's revisionary order under s.263 as beyond jurisdiction. The Tribunal held that revision cannot be predicated on an assessment under s.153A r/w s.143(3) which had been previously quashed for invalid s.153D approval, because doing so would unlawfully extend statutory limitation; a non-est order cannot be said to be erroneous or prejudicial. The AO's considered findings on excess stock (included in books) and on bad debts u/s 36(1)(vii) were not shown to be erroneous; PCIT failed to identify specific legal or factual errors or apply minds on merits. Applying sublato fundamentum cadit opus, the s.263 order was accordingly set aside.
ITAT quashed the PCIT's revisionary order under s.263 as beyond jurisdiction. The Tribunal held that revision cannot be predicated on an assessment under s.153A r/w s.143(3) which had been previously quashed for invalid s.153D approval, because doing so would unlawfully extend statutory limitation; a non-est order cannot be said to be erroneous or prejudicial. The AO's considered findings on excess stock (included in books) and on bad debts u/s 36(1)(vii) were not shown to be erroneous; PCIT failed to identify specific legal or factual errors or apply minds on merits. Applying sublato fundamentum cadit opus, the s.263 order was accordingly set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
