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...
Revision under section 263 was examined regarding additions for allegedly unexplained purchases/sales and allied issues. Where the seller's sales had already been accepted/settled in first appeal, the same transactions could not be treated as unexplained in the purchaser's hands, and the revisional direction could not nullify the CIT(A)'s finding; section 263 jurisdiction was held improperly exercised to that extent. However, for purchases from another supplier whose sales were not shown to have been accepted and where the AO had made a bogus sales addition after PMGKY surrender, the AO's enquiry was held incomplete, justifying set-aside for de novo consideration. The unexplained difference between audited P&L profit and computed income also warranted de novo examination, and audit-objection-based initiation was upheld. Appeal partly allowed. - ITAT
Revision under section 263 was examined regarding additions for allegedly unexplained purchases/sales and allied issues. Where the seller's sales had already been accepted/settled in first appeal, the same transactions could not be treated as unexplained in the purchaser's hands, and the revisional direction could not nullify the CIT(A)'s finding; section 263 jurisdiction was held improperly exercised to that extent. However, for purchases from another supplier whose sales were not shown to have been accepted and where the AO had made a bogus sales addition after PMGKY surrender, the AO's enquiry was held incomplete, justifying set-aside for de novo consideration. The unexplained difference between audited P&L profit and computed income also warranted de novo examination, and audit-objection-based initiation was upheld. Appeal partly allowed. - ITAT
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