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 of 813 days in filing appeal - relevant date - In the present case the said order was passed by original adjudicating authority on 23.11.2020. The same was received by the appellant on 27.11.2020. There is no denial about the said date of Communication. The appeal filed before Commissioner (A) on 25.1.2021 is therefore two days prior the expiry of the statutory period of limitation i.e. 2 months. The findings of the Commissioner (A) are therefore held wrong. - AT
Condonation of delay of 813 days in filing appeal - relevant date - In the present case the said order was passed by original adjudicating authority on 23.11.2020. The same was received by the appellant on 27.11.2020. There is no denial about the said date of Communication. The appeal filed before Commissioner (A) on 25.1.2021 is therefore two days prior the expiry of the statutory period of limitation i.e. 2 months. The findings of the Commissioner (A) are therefore held wrong. - AT
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