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...
For assessment under s.153C, the dominant issue was whether the "date of search" for computing the ten relevant assessment years is the original search date in the searched person's case or the date on which seized material was received by the AO of the non-searched person under the first proviso to s.153C(1). Applying Explanation (1) to s.153A, the Tribunal held that the receipt date is deemed to be the search date for the non-searched person, and the ten assessment years must be counted backward from the end of the assessment year relevant to the previous year in which such deemed search occurred. Since receipt occurred in AY 2022-23, AY 2012-13 fell outside the permissible block; the Revenue's appeal failed. - ITAT
For assessment under s.153C, the dominant issue was whether the "date of search" for computing the ten relevant assessment years is the original search date in the searched person's case or the date on which seized material was received by the AO of the non-searched person under the first proviso to s.153C(1). Applying Explanation (1) to s.153A, the Tribunal held that the receipt date is deemed to be the search date for the non-searched person, and the ten assessment years must be counted backward from the end of the assessment year relevant to the previous year in which such deemed search occurred. Since receipt occurred in AY 2022-23, AY 2012-13 fell outside the permissible block; the Revenue's appeal failed. - ITAT
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