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...
Denial of cross-examination in customs broker licence proceedings breached procedural fairness because the regulation entitled the broker to cross-examine persons examined in support of the charges, and any refusal had to be recorded with written reasons. Where the show cause notice relied on a witness statement to frame the charges and no cross-examination was allowed despite a written request, the proceedings were vitiated. The Revenue's arguments on deemed revocation and non-appearance at personal hearings were not considered, and the issue of a fresh show cause notice after earlier revocation was left open for an appropriate case. The Revenue's appeal was dismissed.
Denial of cross-examination in customs broker licence proceedings breached procedural fairness because the regulation entitled the broker to cross-examine persons examined in support of the charges, and any refusal had to be recorded with written reasons. Where the show cause notice relied on a witness statement to frame the charges and no cross-examination was allowed despite a written request, the proceedings were vitiated. The Revenue's arguments on deemed revocation and non-appearance at personal hearings were not considered, and the issue of a fresh show cause notice after earlier revocation was left open for an appropriate case. The Revenue's appeal was dismissed.
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