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...
Stay on collection/recovery of the tax and interest demands - There is no material change in facts and circumstances of the case as before Their Lordships as before us now. The two companies investing in the assessee before us are Mauritian companies and seem to be special purpose vehicles, and, at the stage of the hearing of stay petition and based on the material before us, it is not possible for us to, even prima facie, take a call on their bonafides and genuineness. - AT
Stay on collection/recovery of the tax and interest demands - There is no material change in facts and circumstances of the case as before Their Lordships as before us now. The two companies investing in the assessee before us are Mauritian companies and seem to be special purpose vehicles, and, at the stage of the hearing of stay petition and based on the material before us, it is not possible for us to, even prima facie, take a call on their bonafides and genuineness. - AT
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