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...
Validity of Reopening of assessment - The initial notices u/s 148 issued on 31st March, 2021 Section 151 of the Act as it stood prior to 1st April, 2021 would apply. In terms thereof, undeniably, the previous sanction for issuance of both the notices was taken only of the Additional CIT and not of either the Principal Chief CIT (for AY 2015-16) or the Principal CIT (for AY 2016-17). - Notices issued 148 are illegal, quashed - HC
Validity of Reopening of assessment - The initial notices u/s 148 issued on 31st March, 2021 Section 151 of the Act as it stood prior to 1st April, 2021 would apply. In terms thereof, undeniably, the previous sanction for issuance of both the notices was taken only of the Additional CIT and not of either the Principal Chief CIT (for AY 2015-16) or the Principal CIT (for AY 2016-17). - Notices issued 148 are illegal, quashed - HC
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