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...
Assessment jurisdiction under search provisions cannot be assumed for unabated years based on third-party digital chats; the third-party WhatsApp material was unrelated, post-facto and not incriminating, consequently the addition was deleted. The revenue bears the onus to prove unrecorded consideration, and reliance on uncorroborated digital chats or 'dumb documents' is impermissible, so the on-money addition failed on merits. Extrapolating modus operandi or materials from another entity or assessment year to make additions is legally unsound; such additions were deleted. Alleged penny stock contrivances lacking incriminating search material and documentary proof were likewise disallowed and revenue appeals dismissed.
Assessment jurisdiction under search provisions cannot be assumed for unabated years based on third-party digital chats; the third-party WhatsApp material was unrelated, post-facto and not incriminating, consequently the addition was deleted. The revenue bears the onus to prove unrecorded consideration, and reliance on uncorroborated digital chats or 'dumb documents' is impermissible, so the on-money addition failed on merits. Extrapolating modus operandi or materials from another entity or assessment year to make additions is legally unsound; such additions were deleted. Alleged penny stock contrivances lacking incriminating search material and documentary proof were likewise disallowed and revenue appeals dismissed.
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