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...
Jurisdiction under section 153C failed because the seized diaries and notebooks were recovered from a third person, did not name the assessee, and contained no identifying material conclusively linking the code "DD" to him. Corroboration from a contact saved as "DD Personal", Truecaller data and other digital material was held too tenuous to supply the missing nexus. Presumptions under sections 132(4A) and 292C were confined to the person from whom the documents were found and could not be transposed to the assessee without independent evidence. The notice, consequential assessment and addition were therefore unsustainable, and the Revenue's appeal was dismissed.
Jurisdiction under section 153C failed because the seized diaries and notebooks were recovered from a third person, did not name the assessee, and contained no identifying material conclusively linking the code "DD" to him. Corroboration from a contact saved as "DD Personal", Truecaller data and other digital material was held too tenuous to supply the missing nexus. Presumptions under sections 132(4A) and 292C were confined to the person from whom the documents were found and could not be transposed to the assessee without independent evidence. The notice, consequential assessment and addition were therefore unsustainable, and the Revenue's appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
