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...
Whether proceedings under Section 153C were validly initiated: Court held the foundational statutory prerequisite-creation of an asset under the scheme and the fourth proviso to Section 153A-appears absent because the ledger entries relate to expenditure and TDS was deducted, undermining the jurisdictional basis for a Section 153C notice; outcome: petitioner has a plausible ground to oppose the proceedings. Direction to assessing officer to decide petitioner's objections and pass a reasoned order within the specified short period, with communication to petitioner. - HC
Whether proceedings under Section 153C were validly initiated: Court held the foundational statutory prerequisite-creation of an asset under the scheme and the fourth proviso to Section 153A-appears absent because the ledger entries relate to expenditure and TDS was deducted, undermining the jurisdictional basis for a Section 153C notice; outcome: petitioner has a plausible ground to oppose the proceedings. Direction to assessing officer to decide petitioner's objections and pass a reasoned order within the specified short period, with communication to petitioner. - HC
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