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 under s.148A(1) was challenged on the ground that the AO lacked "information which suggests that income chargeable to tax has escaped assessment" and instead undertook a roving inquiry based solely on consolidated debit and credit bank entries. The Court held that s.148A(1) permits only verification of such information available on the portal and does not authorize fishing inquiries, particularly when transactions were through banking channels and party-wise details were already available. As the notice and order were founded merely on consolidated bank entries without any further incriminating material, the AO exceeded jurisdiction; the writ petition was allowed. - HC
Reopening under s.148A(1) was challenged on the ground that the AO lacked "information which suggests that income chargeable to tax has escaped assessment" and instead undertook a roving inquiry based solely on consolidated debit and credit bank entries. The Court held that s.148A(1) permits only verification of such information available on the portal and does not authorize fishing inquiries, particularly when transactions were through banking channels and party-wise details were already available. As the notice and order were founded merely on consolidated bank entries without any further incriminating material, the AO exceeded jurisdiction; the writ petition was allowed. - HC
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