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 allowed the assessee's appeal, quashing reassessment proceedings and consequent additions. The Tribunal held the notice under section 148 issued on 30/07/2022 barred by limitation, the six-year period having expired on 31/03/2022, and reiterated that the earlier 30/06/2021 notice could not be salvaged by TOLA. Independently, the section 148A(b) notice dated 27/05/2022 was held invalid for non-supply of the information/material forming the basis of the reasons, thereby vitiating reopening under section 147. Further, additions under section 69A were not sustained: allegations of VAT evasion and unexplained cash were uncorroborated, speculative and unsupported by any cogent cash-trail or material.
ITAT allowed the assessee's appeal, quashing reassessment proceedings and consequent additions. The Tribunal held the notice under section 148 issued on 30/07/2022 barred by limitation, the six-year period having expired on 31/03/2022, and reiterated that the earlier 30/06/2021 notice could not be salvaged by TOLA. Independently, the section 148A(b) notice dated 27/05/2022 was held invalid for non-supply of the information/material forming the basis of the reasons, thereby vitiating reopening under section 147. Further, additions under section 69A were not sustained: allegations of VAT evasion and unexplained cash were uncorroborated, speculative and unsupported by any cogent cash-trail or material.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
