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...
Rectification u/s 154 - Provision for bad and doubtful debts is under Section 36 (1) (viia) - This Court is of the considered opinion that Section 154 cannot be converted as an appeal for entertaining a ground for adjudication of merits or disputable issues. Thus, the scope of Section 154 is undoubtedly limited with reference to the circumstances narrated under the provision itself. - if at all the petitioner is of an opinion that the Authorities may venture into the adjudication of disputed issues, it is for them to place all the judgments and facts with reference to Section 154 of the Income Tax Act. - HC
Rectification u/s 154 - Provision for bad and doubtful debts is under Section 36 (1) (viia) - This Court is of the considered opinion that Section 154 cannot be converted as an appeal for entertaining a ground for adjudication of merits or disputable issues. Thus, the scope of Section 154 is undoubtedly limited with reference to the circumstances narrated under the provision itself. - if at all the petitioner is of an opinion that the Authorities may venture into the adjudication of disputed issues, it is for them to place all the judgments and facts with reference to Section 154 of the Income Tax Act. - HC
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