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...
Denial of opportunity to test third-party evidence by cross-examination breaches natural justice and, where additions rest solely on uncorroborated seized material and a general statement not specifically identifying the taxpayer, such material cannot discharge the Revenue's onus to prove undisclosed consideration; accordingly the addition was unsustainable and deleted. The analysis emphasises that reliance on third-party search material requires both specific linkage to the taxpayer and procedural fairness through disclosure and the right to confront the witness; absent corroboration, the material only raises suspicion and does not justify tax additions.
Denial of opportunity to test third-party evidence by cross-examination breaches natural justice and, where additions rest solely on uncorroborated seized material and a general statement not specifically identifying the taxpayer, such material cannot discharge the Revenue's onus to prove undisclosed consideration; accordingly the addition was unsustainable and deleted. The analysis emphasises that reliance on third-party search material requires both specific linkage to the taxpayer and procedural fairness through disclosure and the right to confront the witness; absent corroboration, the material only raises suspicion and does not justify tax additions.
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