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...
Principles of natural justice - allegation is that SCN issued with a pre- determined and closed mind - it prima-facie appears that the SCN fell into the category of preventive show-cause notice falling under the exception under para-5.0 of the master circular dated 10th March 2017. Had the proceedings not been initiated, the liability of paying service tax might have been evaded - thus, the case of the petitioner comes within the exception to para-5.0 of the master circular dated 10th March 2017. The adjudication order has already been passed on 16th February 2021. - Petition dismissed - HC
Principles of natural justice - allegation is that SCN issued with a pre- determined and closed mind - it prima-facie appears that the SCN fell into the category of preventive show-cause notice falling under the exception under para-5.0 of the master circular dated 10th March 2017. Had the proceedings not been initiated, the liability of paying service tax might have been evaded - thus, the case of the petitioner comes within the exception to para-5.0 of the master circular dated 10th March 2017. The adjudication order has already been passed on 16th February 2021. - Petition dismissed - HC
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