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 Best judgement assessment u/s 144 - the responsibility of the assessee does not end by merely appointing a Counsel. The assessee necessarily needs to ensure and make available all necessary informations to its counsel for enabling him to participate effectively in the hearing. However, in view of the peculiar facts of the present case, considering the oral undertaking given we do not insist on an affidavit of the assessee. Having expressed our displeasure on the lax attitude evident on record, accepting the oral undertaking given, we deem it appropriate to direct a remand. At the same time at this stage we deem it necessary to highlight that a Government Corporation is like any other assessee before the tax authority and cannot be allowed to plead that on this count it be given a preferential treatment and be allowed to escape the responsibilities of representing their case before the other governmental authorities including the tax authorities. - AT
Validity of Best judgement assessment u/s 144 - the responsibility of the assessee does not end by merely appointing a Counsel. The assessee necessarily needs to ensure and make available all necessary informations to its counsel for enabling him to participate effectively in the hearing. However, in view of the peculiar facts of the present case, considering the oral undertaking given we do not insist on an affidavit of the assessee. Having expressed our displeasure on the lax attitude evident on record, accepting the oral undertaking given, we deem it appropriate to direct a remand. At the same time at this stage we deem it necessary to highlight that a Government Corporation is like any other assessee before the tax authority and cannot be allowed to plead that on this count it be given a preferential treatment and be allowed to escape the responsibilities of representing their case before the other governmental authorities including the tax authorities. - AT
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