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...
Reopening of assessment to withdraw deduction was held invalid because the original assessment had merged with an appellate order and the AO, acting on supervisory direction, lacked independent "reason to believe"; further, the recorded reasons did not allege failure to fully and truly disclose material facts, a jurisdictional precondition for reopening beyond four years, so the reassessment was set aside. Deduction under Chapter VI-A was held allowable despite a return filed within the extended time under s.139(4), applying the rule that conflicting views be resolved in favour of the taxpayer, so denial on belated filing was rejected. Interest and allied receipts were treated as having direct nexus with SEZ business, so deduction was sustained. Disallowances for excess depreciation and lease-rent/TDS were directed to be allowed since they did not affect taxable income in view of full profit deduction and CBDT Circular No.37/2016. - ITAT
Reopening of assessment to withdraw deduction was held invalid because the original assessment had merged with an appellate order and the AO, acting on supervisory direction, lacked independent "reason to believe"; further, the recorded reasons did not allege failure to fully and truly disclose material facts, a jurisdictional precondition for reopening beyond four years, so the reassessment was set aside. Deduction under Chapter VI-A was held allowable despite a return filed within the extended time under s.139(4), applying the rule that conflicting views be resolved in favour of the taxpayer, so denial on belated filing was rejected. Interest and allied receipts were treated as having direct nexus with SEZ business, so deduction was sustained. Disallowances for excess depreciation and lease-rent/TDS were directed to be allowed since they did not affect taxable income in view of full profit deduction and CBDT Circular No.37/2016. - ITAT
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