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...
Condonation of delay in filing application - delay on the ground that the impugned order was not served - Even otherwise, it is evident from the said application that the appellant was aware on August 17, 2016 that an order had been passed on March 15, 2016 by the Commissioner after the personal hearing was conducted on March 8, 2016. Thus, when the appellant, even according to his own statement, was aware that an order had been passed on March 15, 2016, then the appellant should have taken immediate steps to obtain the order so that the appeal could be filed within the three months from the said date, but as it transpires the appeal was actually filed on October 25, 2019 after a period of almost three years and two months. - AT
Condonation of delay in filing application - delay on the ground that the impugned order was not served - Even otherwise, it is evident from the said application that the appellant was aware on August 17, 2016 that an order had been passed on March 15, 2016 by the Commissioner after the personal hearing was conducted on March 8, 2016. Thus, when the appellant, even according to his own statement, was aware that an order had been passed on March 15, 2016, then the appellant should have taken immediate steps to obtain the order so that the appeal could be filed within the three months from the said date, but as it transpires the appeal was actually filed on October 25, 2019 after a period of almost three years and two months. - AT
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