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...
Adjustment of refund against outstanding demand - non fulfillment of conditions of prior intimation u/s 245 - it can be seen that the allegation that there was no prior intimation under section 245 of the Act has remained unrebutted as no proof of any such prior intimation was placed on record by the Revenue - thus the impugned action of respondent No.2 in making, adjustments of the amount for assessment year 2008-09 against the alleged outstanding, demands for assessment years 2014-15 and 2015-16 is bad and illegal and is accordingly quashed. - HC
Adjustment of refund against outstanding demand - non fulfillment of conditions of prior intimation u/s 245 - it can be seen that the allegation that there was no prior intimation under section 245 of the Act has remained unrebutted as no proof of any such prior intimation was placed on record by the Revenue - thus the impugned action of respondent No.2 in making, adjustments of the amount for assessment year 2008-09 against the alleged outstanding, demands for assessment years 2014-15 and 2015-16 is bad and illegal and is accordingly quashed. - HC
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