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...
Assessment u/s 144C - issuance of draft order as mandatory and contemplated u/s 144(C) not adhered to - Once the procedure has been followed and the Appellate Tribunal remitted the matter back to decide the particular issue with a specific finding, then it is sufficient if the remitted issue was decided by the AO / TPO and a final assessment order is passed. - Repetition of the same procedures would become an empty formality, which is not intended under the provision - HC
Assessment u/s 144C - issuance of draft order as mandatory and contemplated u/s 144(C) not adhered to - Once the procedure has been followed and the Appellate Tribunal remitted the matter back to decide the particular issue with a specific finding, then it is sufficient if the remitted issue was decided by the AO / TPO and a final assessment order is passed. - Repetition of the same procedures would become an empty formality, which is not intended under the provision - HC
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