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...
Validity of assessment order u/s 144-C (4) - period of limitation - Neither Circular no.8/2021 nor notification no.74/2021 dated 25.6.2021 or press release dated 25.6.2021 would help respondent no.1. - it only provides for extension of time for filing of objections. It does not extend time for passing order under sub-section 4 of Section 144-C of the Act. In any case, even if, we proceed on the basis that, it would extend time to pass orders, still, as admitted in affidavit in reply itself, time to pass such order would have expired on 30.6.2021. - HC
Validity of assessment order u/s 144-C (4) - period of limitation - Neither Circular no.8/2021 nor notification no.74/2021 dated 25.6.2021 or press release dated 25.6.2021 would help respondent no.1. - it only provides for extension of time for filing of objections. It does not extend time for passing order under sub-section 4 of Section 144-C of the Act. In any case, even if, we proceed on the basis that, it would extend time to pass orders, still, as admitted in affidavit in reply itself, time to pass such order would have expired on 30.6.2021. - HC
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