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...
An agreement must be read as a whole; on that basis the authorities correctly found that the JDA constituted a transfer of land chargeable in AY 2005 06, but the court directed that capital gains should not be taxed again in AY 2005 06 where the same sale consideration has already been subjected to tax in AYs 2007 08 and 2008 09. The principle that income is taxable in the relevant assessment year and in the hands of the correct assessee was applied, and the capital gains addition for AY 2005 06 was set aside subject to verification by the Assessing Officer that the consideration was already taxed later.
An agreement must be read as a whole; on that basis the authorities correctly found that the JDA constituted a transfer of land chargeable in AY 2005 06, but the court directed that capital gains should not be taxed again in AY 2005 06 where the same sale consideration has already been subjected to tax in AYs 2007 08 and 2008 09. The principle that income is taxable in the relevant assessment year and in the hands of the correct assessee was applied, and the capital gains addition for AY 2005 06 was set aside subject to verification by the Assessing Officer that the consideration was already taxed later.
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