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 article examines application of the second proviso to section 153A, holding that initiation of search causes pending assessments to abate and post-search completion under section 143(3) is invalid; consequentially the 143(3) order was quashed. It emphasises that additions under section 153A are confined to incriminating material unearthed in search and deleted an addition for alleged suppressed sales for lack of cogent evidence. It further recognises prior period maintenance and sales tax/VAT write offs as allowable business expenditure under section 37(1), and treats write off of capital work in progress on an abandoned retail project as revenue expenditure where no enduring asset resulted.
The article examines application of the second proviso to section 153A, holding that initiation of search causes pending assessments to abate and post-search completion under section 143(3) is invalid; consequentially the 143(3) order was quashed. It emphasises that additions under section 153A are confined to incriminating material unearthed in search and deleted an addition for alleged suppressed sales for lack of cogent evidence. It further recognises prior period maintenance and sales tax/VAT write offs as allowable business expenditure under section 37(1), and treats write off of capital work in progress on an abandoned retail project as revenue expenditure where no enduring asset resulted.
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