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...
Validity of reassessment order u/s 147 - order was not uploaded online - Procedure followed by the revenue in time barring assessments is that while the order may not be uploaded immediately, a DIN number is generated and the order of assessment sent manually. In the present case, the DIN number appears to have been issued on 28.12.2019 and the assessment order in hard copy issued on the same date franked by the post office on 30.12.2019 and served upon the assessee on 02.01.2020, (though returned) with the endorsement 'left'. - Since the order has been received only now, appeal to be filed within 30 days - HC
Validity of reassessment order u/s 147 - order was not uploaded online - Procedure followed by the revenue in time barring assessments is that while the order may not be uploaded immediately, a DIN number is generated and the order of assessment sent manually. In the present case, the DIN number appears to have been issued on 28.12.2019 and the assessment order in hard copy issued on the same date franked by the post office on 30.12.2019 and served upon the assessee on 02.01.2020, (though returned) with the endorsement 'left'. - Since the order has been received only now, appeal to be filed within 30 days - HC
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