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...
Assessment u/s 153A r.w.s. 153C - Block period - Period of limitation - Where two assessments may result, in the case of a searched entity and the related person, both emanating from the same search, but relating to two different sets of assessment years. This certainly cannot be the intention of the Legislature. In fact, the decisions of the Delhi High Court are dated 30.10.2015 and 17.08.2017 and this, perhaps, would have been the reason for insertion of the portion within parenthesis in Section 153C(1). That is, and in the interests of clarity, the block period as applicable to a noticee under Section 153C will be the same as the years constituting the block in the case of the noticee under Section 153A. The two periods are aligned. This issue is accordingly answered, adverse to the petitioner. - HC
Assessment u/s 153A r.w.s. 153C - Block period - Period of limitation - Where two assessments may result, in the case of a searched entity and the related person, both emanating from the same search, but relating to two different sets of assessment years. This certainly cannot be the intention of the Legislature. In fact, the decisions of the Delhi High Court are dated 30.10.2015 and 17.08.2017 and this, perhaps, would have been the reason for insertion of the portion within parenthesis in Section 153C(1). That is, and in the interests of clarity, the block period as applicable to a noticee under Section 153C will be the same as the years constituting the block in the case of the noticee under Section 153A. The two periods are aligned. This issue is accordingly answered, adverse to the petitioner. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
