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...
Penalty under s. 271AAB(1A) was examined on whether the amount offered during search and assessed as unexplained money under s. 69A read with s. 115BBE qualified as "undisclosed income" under Explanation (c) to s. 271AAB. The definition requires income to be represented by money/bullion/jewellery/valuable article, or to be evidenced by entries or documents/transactions found during the s. 132 search. Since the quantum proceedings had already found that no incriminating material was recovered to support the addition, the statutory precondition failed, and the sum could not be treated as "undisclosed income"; the penalty was directed to be deleted and the appeal was allowed. - ITAT
Penalty under s. 271AAB(1A) was examined on whether the amount offered during search and assessed as unexplained money under s. 69A read with s. 115BBE qualified as "undisclosed income" under Explanation (c) to s. 271AAB. The definition requires income to be represented by money/bullion/jewellery/valuable article, or to be evidenced by entries or documents/transactions found during the s. 132 search. Since the quantum proceedings had already found that no incriminating material was recovered to support the addition, the statutory precondition failed, and the sum could not be treated as "undisclosed income"; the penalty was directed to be deleted and the appeal was allowed. - ITAT
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