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...
Eligibility to file settlement application - benefit of extension of time to file application for settlement - Admittedly, in this case, application for settlement under Section 245C(1) of the Act was filed on 17th March, 2021 while the Settlement Commission had ceased to operate w.e.f. 1st February, 2021 in view of the aforesaid Finance Act, 2021 amending the provisions of the Act. - So far as challenged to the legality and validity of the order of the aforesaid order of Central Board of Direct Taxes dated 28th September, 2021, on the ground of discrimination in exercise of power under Section 119 (2) (b) of the Income Tax Act, 1961 is concerned, we hold the said order of the Board as constitutionally valid and legal and is perfectly within the power conferred upon it - HC
Eligibility to file settlement application - benefit of extension of time to file application for settlement - Admittedly, in this case, application for settlement under Section 245C(1) of the Act was filed on 17th March, 2021 while the Settlement Commission had ceased to operate w.e.f. 1st February, 2021 in view of the aforesaid Finance Act, 2021 amending the provisions of the Act. - So far as challenged to the legality and validity of the order of the aforesaid order of Central Board of Direct Taxes dated 28th September, 2021, on the ground of discrimination in exercise of power under Section 119 (2) (b) of the Income Tax Act, 1961 is concerned, we hold the said order of the Board as constitutionally valid and legal and is perfectly within the power conferred upon it - HC
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