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...
HC held that invocation of section 153C requires concurrent satisfaction by the AOs of the searched person and the non-searched person that seized property or documents relate to a person other than the searched person; no such satisfaction was recorded. The impugned assessment did not rest on incriminating material found against the petitioner during search/seizure, but on information from the investigation unit and evidence collected during and after search proceedings. Consequently, the assessment under section 147 was proper and invocation of sections 153A/153C was unwarranted. The petitioner's challenge to framing proceedings under section 153C was rejected and the assessment under section 147 upheld.
HC held that invocation of section 153C requires concurrent satisfaction by the AOs of the searched person and the non-searched person that seized property or documents relate to a person other than the searched person; no such satisfaction was recorded. The impugned assessment did not rest on incriminating material found against the petitioner during search/seizure, but on information from the investigation unit and evidence collected during and after search proceedings. Consequently, the assessment under section 147 was proper and invocation of sections 153A/153C was unwarranted. The petitioner's challenge to framing proceedings under section 153C was rejected and the assessment under section 147 upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
