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...
Validity of reopening under section 147/148 is contested on the ground that the sanction required from the competent authority was not obtained; the notice issued in AY 2015-16 on 28 March 2021 falls within the temporal ratio of the cited Supreme Court authority, but was quashed because the sanction stated on the notice was from the CIT (Exemption) rather than the Joint Commissioner mandated by law, and Revenue cannot contradict the express language of the notice regarding whose satisfaction was obtained. The necessity for sanction by the specific authority is determinative, leading to invalidation of the notice.
Validity of reopening under section 147/148 is contested on the ground that the sanction required from the competent authority was not obtained; the notice issued in AY 2015-16 on 28 March 2021 falls within the temporal ratio of the cited Supreme Court authority, but was quashed because the sanction stated on the notice was from the CIT (Exemption) rather than the Joint Commissioner mandated by law, and Revenue cannot contradict the express language of the notice regarding whose satisfaction was obtained. The necessity for sanction by the specific authority is determinative, leading to invalidation of the notice.
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