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...
Reassessment based on an audit objection was quashed where the same CSR-related deduction under Section 80G had already been specifically examined in the original assessment. The Court held that the assessing officer had raised queries, received replies and supporting documents, and substantially allowed the claim earlier, so reopening on the same record amounted to a mere change of opinion. It reaffirmed that reassessment under Sections 147 and 148 cannot be used as a power of review or to re-examine material already considered. The notices under Section 148A(b), the order under Section 148A(d), and the notice under Section 148 were therefore set aside, while all other grounds were left open.
Reassessment based on an audit objection was quashed where the same CSR-related deduction under Section 80G had already been specifically examined in the original assessment. The Court held that the assessing officer had raised queries, received replies and supporting documents, and substantially allowed the claim earlier, so reopening on the same record amounted to a mere change of opinion. It reaffirmed that reassessment under Sections 147 and 148 cannot be used as a power of review or to re-examine material already considered. The notices under Section 148A(b), the order under Section 148A(d), and the notice under Section 148 were therefore set aside, while all other grounds were left open.
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