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...
Rectification u/s 154 - Period of limitation - Late fee u/s. 234E - as per sub-section (7) of Section 154 of the Act, as no amendment under the said section shall be made after expiry of four years from the end of the financial year in which the order sought to be rectified was passed, therefore, the applications filed by the assessee seeking rectification of the orders passed by the DCIT, CPC-TDS u/s. 200A of the Act on 06.09.2014 by filing rectification letters dated 02.02.2022 for the aforementioned respective years were in itself not maintainable. - AT
Rectification u/s 154 - Period of limitation - Late fee u/s. 234E - as per sub-section (7) of Section 154 of the Act, as no amendment under the said section shall be made after expiry of four years from the end of the financial year in which the order sought to be rectified was passed, therefore, the applications filed by the assessee seeking rectification of the orders passed by the DCIT, CPC-TDS u/s. 200A of the Act on 06.09.2014 by filing rectification letters dated 02.02.2022 for the aforementioned respective years were in itself not maintainable. - AT
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