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 estate is assessable under section 168 on income accruing from a deceased person's assets after death, and TDS credit on dividend income belongs to the estate only if the income relates wholly to the post-death period. The ITAT found the legal position undisputed but the record insufficient to decide the relevant period, so the Assessing Officer was directed to verify that fact and grant TDS credit accordingly if the income was post-death. It also held that the Addl./Joint CIT(A) had no power to remand the matter to the Assessing Officer under section 251 in the circumstances, and disapproved that course.
An estate is assessable under section 168 on income accruing from a deceased person's assets after death, and TDS credit on dividend income belongs to the estate only if the income relates wholly to the post-death period. The ITAT found the legal position undisputed but the record insufficient to decide the relevant period, so the Assessing Officer was directed to verify that fact and grant TDS credit accordingly if the income was post-death. It also held that the Addl./Joint CIT(A) had no power to remand the matter to the Assessing Officer under section 251 in the circumstances, and disapproved that course.
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