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...
Cancellation of petitioner's registration - rejection of petition on the ground of time limitation - That being the intent of the Government to grant relaxation of limitation with respect to an order for cancellation of registration, it would defy plain logic to restrict that benefit to proceedings for revocation on such orders and to not extend the same to appeal proceedings. That construction if made, would give rise to an absurd situation. There would exist two dates of order cancelling a registration - one for the purpose of filing an application to revoke that order and another to file appeal there against. - The appellate authority has clearly erred in rejecting the appeal as time barred. - HC
Cancellation of petitioner's registration - rejection of petition on the ground of time limitation - That being the intent of the Government to grant relaxation of limitation with respect to an order for cancellation of registration, it would defy plain logic to restrict that benefit to proceedings for revocation on such orders and to not extend the same to appeal proceedings. That construction if made, would give rise to an absurd situation. There would exist two dates of order cancelling a registration - one for the purpose of filing an application to revoke that order and another to file appeal there against. - The appellate authority has clearly erred in rejecting the appeal as time barred. - HC
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