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...
Under the faceless assessment framework, specialized units (Assessment, Verification, Technical, Review) must conduct or procure factual verification when complex technical claims arise. The Principal Commissioner found the assessment silent on actuarial valuation of post employment benefit remeasurement, payments vis a vis tax deductibility rules, and adjustments for realized foreign exchange gains to capital assets, with no Verification Unit report or recorded enquiries. That absence amounted to a lack of enquiry rather than mere inadequate enquiry; consequence: the assessment was set aside and the Assessing Officer directed to carry out proper verification and pass a fresh order after allowing the taxpayer opportunity to be heard.
Under the faceless assessment framework, specialized units (Assessment, Verification, Technical, Review) must conduct or procure factual verification when complex technical claims arise. The Principal Commissioner found the assessment silent on actuarial valuation of post employment benefit remeasurement, payments vis a vis tax deductibility rules, and adjustments for realized foreign exchange gains to capital assets, with no Verification Unit report or recorded enquiries. That absence amounted to a lack of enquiry rather than mere inadequate enquiry; consequence: the assessment was set aside and the Assessing Officer directed to carry out proper verification and pass a fresh order after allowing the taxpayer opportunity to be heard.
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