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...
Reopening of assessment under income tax law was challenged after a capital reduction where payment to shareholders used the securities premium account. The taxpayer produced ledger entries, share certificates, tax residence certificates, ROC registration of capital reduction and remittance proofs in response to AO queries. The commentary concludes that the taxpayer had made full and true disclosure of material facts, Explanation (1) to the reopening provision did not apply, and the reopening failed to satisfy the proviso criteria; consequently the reassessment was held invalid and the appeal allowed.
Reopening of assessment under income tax law was challenged after a capital reduction where payment to shareholders used the securities premium account. The taxpayer produced ledger entries, share certificates, tax residence certificates, ROC registration of capital reduction and remittance proofs in response to AO queries. The commentary concludes that the taxpayer had made full and true disclosure of material facts, Explanation (1) to the reopening provision did not apply, and the reopening failed to satisfy the proviso criteria; consequently the reassessment was held invalid and the appeal allowed.
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