Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
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Specified-violation provisions for cancellation of trust registration apply prospectively from 1 April 2022; conduct preceding that date cannot support retrospective cancellation on that basis. Cancellation requires identification of the applicable statutory trigger and precise violation, an inquiry reaching satisfaction, and a meaningful opportunity to respond; a notice broadly combining cancellation and exemption-disallowance provisions is insufficient. Jurisdiction transferred under section 127 extends to all proceedings and permits cancellation by a Principal Commissioner or Commissioner. Alleged benefits to specified persons may affect exemption or tax diverted income but, unless they fall within a specified violation, do not alone justify cancellation. Retracted and uncorroborated evidence requires proper examination and cross-examination.
Specified-violation provisions for cancellation of trust registration apply prospectively from 1 April 2022; conduct preceding that date cannot support retrospective cancellation on that basis. Cancellation requires identification of the applicable statutory trigger and precise violation, an inquiry reaching satisfaction, and a meaningful opportunity to respond; a notice broadly combining cancellation and exemption-disallowance provisions is insufficient. Jurisdiction transferred under section 127 extends to all proceedings and permits cancellation by a Principal Commissioner or Commissioner. Alleged benefits to specified persons may affect exemption or tax diverted income but, unless they fall within a specified violation, do not alone justify cancellation. Retracted and uncorroborated evidence requires proper examination and cross-examination.
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