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...
Rectification proceedings invoked to recompute depreciation were held beyond the scope of the apparent mistake remedy because such powers address only manifest errors on the record and not detailed re-assessment; consequence: rectification to re-compute depreciation is invalid. Reopening of assessment was invalidated where the reasons and supervisory approval relied on incorrect AY references and unchecked figures, demonstrating non-application of mind and reliance on irrelevant information; consequence: the reopening notice vitiated for want of proper jurisdictional foundation and in favour of the assessee.
Rectification proceedings invoked to recompute depreciation were held beyond the scope of the apparent mistake remedy because such powers address only manifest errors on the record and not detailed re-assessment; consequence: rectification to re-compute depreciation is invalid. Reopening of assessment was invalidated where the reasons and supervisory approval relied on incorrect AY references and unchecked figures, demonstrating non-application of mind and reliance on irrelevant information; consequence: the reopening notice vitiated for want of proper jurisdictional foundation and in favour of the assessee.
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