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 reassessment orders for AYs 2013-14 and 2014-15, finding jurisdictional defects: the assessing authorities failed to supply the sanction under section 151 and the material relied upon in the reasons recorded under section 148(2), and the effective addition for AY 2014-15 (₹31,50,213) fell below the monetary threshold in section 149(1)(b), rendering reopening invalid. For AY 2018-19, the assessment was quashed because the order did not specify which deeming provisions (sections 68-69D) were invoked for alleged unaccounted income from accommodation entries, vitiating the assumption of jurisdiction. For AY 2021-22 the approval dated 28.06.2022 was held to be mechanically recorded ("Approved"), thus invalidating the sanction and the consequential assessment.
ITAT quashed the reassessment orders for AYs 2013-14 and 2014-15, finding jurisdictional defects: the assessing authorities failed to supply the sanction under section 151 and the material relied upon in the reasons recorded under section 148(2), and the effective addition for AY 2014-15 (₹31,50,213) fell below the monetary threshold in section 149(1)(b), rendering reopening invalid. For AY 2018-19, the assessment was quashed because the order did not specify which deeming provisions (sections 68-69D) were invoked for alleged unaccounted income from accommodation entries, vitiating the assumption of jurisdiction. For AY 2021-22 the approval dated 28.06.2022 was held to be mechanically recorded ("Approved"), thus invalidating the sanction and the consequential assessment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
