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...
Project Import - De-registration of the contracts registered by petitioner - Delayed adjudication and new objection raised by the revenue after 30 years of re-export - Though there is no time limit prescribed, that would not mean that the department could commence adjudication proceedings after 20 or 25 or 30 years by calling upon parties to comply with alleged obligations which they had. That would also amount to violating the principles of natural justice, in as much as, long delay will deprive a party from marshaling the documents or witnesses as there is always a possibility of documents or the witnesses disappearing or ceasing to exist after such a long gap. - HC
Project Import - De-registration of the contracts registered by petitioner - Delayed adjudication and new objection raised by the revenue after 30 years of re-export - Though there is no time limit prescribed, that would not mean that the department could commence adjudication proceedings after 20 or 25 or 30 years by calling upon parties to comply with alleged obligations which they had. That would also amount to violating the principles of natural justice, in as much as, long delay will deprive a party from marshaling the documents or witnesses as there is always a possibility of documents or the witnesses disappearing or ceasing to exist after such a long gap. - HC
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