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 dismissed the assessee's appeal and upheld the PCIT's revisional order u/s 263. It held that the reassessment order dated 30.03.2023 was an "order" independent of the original assessment and was within the limitation period prescribed in s.263(2), hence not barred by limitation. Adequate opportunity of hearing was found to have been afforded through multiple notices and written submissions, satisfying the requirement of s.263, including by electronic mode as per s.2(23C). The AO's failure to disallow delayed employees' PF/ESI contributions, contrary to s.36(1)(va) and binding precedent, rendered the reassessment order both erroneous and prejudicial to the revenue. The ground on customs duty fine/penalty was not pressed and stood rejected.
ITAT dismissed the assessee's appeal and upheld the PCIT's revisional order u/s 263. It held that the reassessment order dated 30.03.2023 was an "order" independent of the original assessment and was within the limitation period prescribed in s.263(2), hence not barred by limitation. Adequate opportunity of hearing was found to have been afforded through multiple notices and written submissions, satisfying the requirement of s.263, including by electronic mode as per s.2(23C). The AO's failure to disallow delayed employees' PF/ESI contributions, contrary to s.36(1)(va) and binding precedent, rendered the reassessment order both erroneous and prejudicial to the revenue. The ground on customs duty fine/penalty was not pressed and stood rejected.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
