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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...
Requirement of pre-deposit - The appellant has not made the pre-deposit and has filed an application seeking waiver because of financial constraints and for the reason that the appellant has a good case on merits - As the law relating to pre-deposit has been settled by the Supreme Court and the High Courts, it would also not be possible to accept the prayer made by the learned counsel for the appellant that the application should not be decided at this stage as the matter in the case of a co-noticee, after his plea for waiver of pre-deposit had been rejected by the Tribunal and the High Court had maintained the order of the Tribunal, is pending in Supreme Court. - The application filed for waiver of pre-deposit is rejected - As the application has been rejected, the appeal stands dismissed - AT
Requirement of pre-deposit - The appellant has not made the pre-deposit and has filed an application seeking waiver because of financial constraints and for the reason that the appellant has a good case on merits - As the law relating to pre-deposit has been settled by the Supreme Court and the High Courts, it would also not be possible to accept the prayer made by the learned counsel for the appellant that the application should not be decided at this stage as the matter in the case of a co-noticee, after his plea for waiver of pre-deposit had been rejected by the Tribunal and the High Court had maintained the order of the Tribunal, is pending in Supreme Court. - The application filed for waiver of pre-deposit is rejected - As the application has been rejected, the appeal stands dismissed - AT
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