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 against non existent company [company merged] - assessment in the hands of the successor - Whatever action has done in the past by their share applicants cannot be investigated in the hands of the assessee after amalgamation. Therefore, we are of the view that in view of the National Company Law Tribunal’s decision on the amalgamation petition, no inquiry could be made in the hands of both these assessees qua the antecedents of merged companies. - AT
Assessment against non existent company [company merged] - assessment in the hands of the successor - Whatever action has done in the past by their share applicants cannot be investigated in the hands of the assessee after amalgamation. Therefore, we are of the view that in view of the National Company Law Tribunal’s decision on the amalgamation petition, no inquiry could be made in the hands of both these assessees qua the antecedents of merged companies. - AT
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