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...
Explanation 4 to section 28 preserved the pre-amendment customs recovery regime for notices issued before 29-03-2018, so the later supplementary-notice mechanism under section 28(7A) and the 2019 Regulations could not be applied to a 2014 show cause notice. A corrigendum adding fresh allegations and evidence after completion of the final hearing could not be treated as a valid supplement to the notice and had to be ignored at final adjudication. The writ petition was allowed, and the final order was directed to be passed on the original notice without considering the corrigendum.
Explanation 4 to section 28 preserved the pre-amendment customs recovery regime for notices issued before 29-03-2018, so the later supplementary-notice mechanism under section 28(7A) and the 2019 Regulations could not be applied to a 2014 show cause notice. A corrigendum adding fresh allegations and evidence after completion of the final hearing could not be treated as a valid supplement to the notice and had to be ignored at final adjudication. The writ petition was allowed, and the final order was directed to be passed on the original notice without considering the corrigendum.
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