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.270A for "underreporting of income" was challenged on the ground that the assessed addition was made on an estimated basis by lump-sum disallowance of expenses. The Tribunal held that estimated additions are excluded under s.270A(6) only where the accounts are found correct and complete but income cannot be properly deduced from the method employed; here the AO recorded that the books were not correct and complete due to discrepancies and unsupported vouchers, which remained unrebutted, hence penalty was sustainable. Penalty on disallowance under s.40(a)(ia) for TDS default was also upheld as no contrary submissions were made; appeal was dismissed. - ITAT
Penalty under s.270A for "underreporting of income" was challenged on the ground that the assessed addition was made on an estimated basis by lump-sum disallowance of expenses. The Tribunal held that estimated additions are excluded under s.270A(6) only where the accounts are found correct and complete but income cannot be properly deduced from the method employed; here the AO recorded that the books were not correct and complete due to discrepancies and unsupported vouchers, which remained unrebutted, hence penalty was sustainable. Penalty on disallowance under s.40(a)(ia) for TDS default was also upheld as no contrary submissions were made; appeal was dismissed. - ITAT
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