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...
Dominant issue: whether the taxpayer could claim the new tax regime under section 115BAC despite delayed filing of Form 10-IE and a slightly late return. Reasoning: while jurisprudence treats late Form 10-IE as a procedural lapse that ordinarily should not forfeit the new regime, the return itself was filed late, rendering the new-regime option infirm and requiring reassessment under the old regime. Outcome: matter remanded to the Assessing Officer to admit and verify alternative claims for deductions under sections 80C and 80TTA and grant relief if substantiated; appeal allowed for statistical purposes. - ITAT
Dominant issue: whether the taxpayer could claim the new tax regime under section 115BAC despite delayed filing of Form 10-IE and a slightly late return. Reasoning: while jurisprudence treats late Form 10-IE as a procedural lapse that ordinarily should not forfeit the new regime, the return itself was filed late, rendering the new-regime option infirm and requiring reassessment under the old regime. Outcome: matter remanded to the Assessing Officer to admit and verify alternative claims for deductions under sections 80C and 80TTA and grant relief if substantiated; appeal allowed for statistical purposes. - ITAT
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