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...
Invocation of extended period of limitation - Levy of interest u/s 75 and penalty u/s 78 - the appellant is working as a nodal agency for the Government Project(s) and are not a Commercial Organisation in the true sense. Further, there is no allegation of suppression or any falsification of the accounts. From the allegations and facts on record, it is observed that these are attributable to the clerical error and lack of proper reconciliation at the time of audit, and before the court below - the extended period of limitation is not invokable. Accordingly, penalty under Section 78 is set aside. - AT
Invocation of extended period of limitation - Levy of interest u/s 75 and penalty u/s 78 - the appellant is working as a nodal agency for the Government Project(s) and are not a Commercial Organisation in the true sense. Further, there is no allegation of suppression or any falsification of the accounts. From the allegations and facts on record, it is observed that these are attributable to the clerical error and lack of proper reconciliation at the time of audit, and before the court below - the extended period of limitation is not invokable. Accordingly, penalty under Section 78 is set aside. - AT
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