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...
The note addresses whether documents seized from a person other than the assessee fall within the phrase 'found in the course of search' and thus may support assessment under section 153A; it records that such material (seized from an employee covered by the same search) is within that scope, but stresses that for an unabated assessment additions under 153A require incriminating material unearthed by the search. The seized document was held non incriminating, and therefore the 153A assessment based on it is invalid; a late challenge to approval and introduction of fresh appellate grounds was rejected for want of record support.
The note addresses whether documents seized from a person other than the assessee fall within the phrase 'found in the course of search' and thus may support assessment under section 153A; it records that such material (seized from an employee covered by the same search) is within that scope, but stresses that for an unabated assessment additions under 153A require incriminating material unearthed by the search. The seized document was held non incriminating, and therefore the 153A assessment based on it is invalid; a late challenge to approval and introduction of fresh appellate grounds was rejected for want of record support.
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