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...
Assessments pursuant to search were held time-barred under s.153B because the search legally concluded on 20.02.2021, when the authorised officer completed the physical search and drew the last valid panchanama; the later visit on 20.04.2021 merely lifted a restraint under s.132(3) without any further search activity or fresh authorisation and could not extend limitation. The restraint orders under s.132(3) were also found invalid as the records did not show why seizure was "not practicable," and, in any event, revocation beyond the CBDT-mandated one-month period rendered subsequent panchanamas incapable of extending limitation. Consequently, assessments for AYs 2020-21 and 2021-22 were quashed as barred by limitation. - ITAT
Assessments pursuant to search were held time-barred under s.153B because the search legally concluded on 20.02.2021, when the authorised officer completed the physical search and drew the last valid panchanama; the later visit on 20.04.2021 merely lifted a restraint under s.132(3) without any further search activity or fresh authorisation and could not extend limitation. The restraint orders under s.132(3) were also found invalid as the records did not show why seizure was "not practicable," and, in any event, revocation beyond the CBDT-mandated one-month period rendered subsequent panchanamas incapable of extending limitation. Consequently, assessments for AYs 2020-21 and 2021-22 were quashed as barred by limitation. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
