Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
ITAT reviewed cancellation of a charitable institution's registration under 10(23C)(vi) and found the cancellation relied on unverified adverse inferences from minor discrepancies rather than a proper enquiry; the tribunal held that issues like duplicate receipts, advance land payments, lease-versus-asset characterisation and small expenditures required detailed scrutiny or assessment (including examination under provisions governing inurement) rather than summary revocation. Applying the proviso and Explanation 2, the recorded reasons did not establish satisfaction of specified violations prior to cancellation; the cancellation order was set aside and registration restored.
ITAT reviewed cancellation of a charitable institution's registration under 10(23C)(vi) and found the cancellation relied on unverified adverse inferences from minor discrepancies rather than a proper enquiry; the tribunal held that issues like duplicate receipts, advance land payments, lease-versus-asset characterisation and small expenditures required detailed scrutiny or assessment (including examination under provisions governing inurement) rather than summary revocation. Applying the proviso and Explanation 2, the recorded reasons did not establish satisfaction of specified violations prior to cancellation; the cancellation order was set aside and registration restored.
Note: It is a system-generated summary and is for quick reference only.