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...
Amalgamation assessment: the commentary concludes that income and disallowances of a predecessor for a period prior to amalgamation cannot be merged into a single reassessment order framed against the successor; such pre-amalgamation amounts must be assessed separately and, if at all, only under representative assessment provisions, and reliance on decisions about notices in the name of non-existent entities does not justify clubbing the predecessors income with the successors in one composite assessment. The revenues reassessment attempts to add predecessor period income in a single order are therefore unsustainable.
Amalgamation assessment: the commentary concludes that income and disallowances of a predecessor for a period prior to amalgamation cannot be merged into a single reassessment order framed against the successor; such pre-amalgamation amounts must be assessed separately and, if at all, only under representative assessment provisions, and reliance on decisions about notices in the name of non-existent entities does not justify clubbing the predecessors income with the successors in one composite assessment. The revenues reassessment attempts to add predecessor period income in a single order are therefore unsustainable.
Note: It is a system-generated summary and is for quick reference only.