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 of an assessment order extinguished the earlier addition made for share premium, merging the rectified order with the original assessment and preventing appellate re-adjudication; consequently the deletion effected by the assessing officer under rectification stands effective. Separately, where share subscribers were non-residents and no evidence supported domestic place of effective management, the valuation provision for share premium did not apply to shares issued to non-resident subscribers, so the addition was unsustainable on merits and deleted.
Rectification of an assessment order extinguished the earlier addition made for share premium, merging the rectified order with the original assessment and preventing appellate re-adjudication; consequently the deletion effected by the assessing officer under rectification stands effective. Separately, where share subscribers were non-residents and no evidence supported domestic place of effective management, the valuation provision for share premium did not apply to shares issued to non-resident subscribers, so the addition was unsustainable on merits and deleted.
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