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...
Levy of penalty on Director u/r 26 of CER - involvement of the director of the appellants in clandestine activities or not - here are not much reasoning has been assigned by the said order, to show that Director was having mens rea or direct involvement for invocation of Rule 26 - Since the impugned order fails to establish the ingredient of “mens rea” on the part of the Appellant 2 who was otherwise performing their duties as employee of the company, the penalties imposed on the Director, cannot be upheld. - AT
Levy of penalty on Director u/r 26 of CER - involvement of the director of the appellants in clandestine activities or not - here are not much reasoning has been assigned by the said order, to show that Director was having mens rea or direct involvement for invocation of Rule 26 - Since the impugned order fails to establish the ingredient of “mens rea” on the part of the Appellant 2 who was otherwise performing their duties as employee of the company, the penalties imposed on the Director, cannot be upheld. - AT
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