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 BMA was held to operate prospectively from A.Y. 2016-17, with the proviso to section 3(1) allowing only limited retrospective valuation of an undisclosed asset when it first comes to the AO's notice. An explained inherited corpus and voluntarily disclosed historic interest were not "undisclosed assets" under sections 2(11) and 4(1), so the BMA could not be used to tax them; any pre-2016 income had to be dealt with under the IT Act. The notice under section 10(1) was also jurisdictionally defective because it omitted the relevant year and was issued belatedly. A.Y. 2019-20 was not the correct year of chargeability; at most, the proviso could point to A.Y. 2017-18.
The BMA was held to operate prospectively from A.Y. 2016-17, with the proviso to section 3(1) allowing only limited retrospective valuation of an undisclosed asset when it first comes to the AO's notice. An explained inherited corpus and voluntarily disclosed historic interest were not "undisclosed assets" under sections 2(11) and 4(1), so the BMA could not be used to tax them; any pre-2016 income had to be dealt with under the IT Act. The notice under section 10(1) was also jurisdictionally defective because it omitted the relevant year and was issued belatedly. A.Y. 2019-20 was not the correct year of chargeability; at most, the proviso could point to A.Y. 2017-18.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
