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...
Extended period of limitation - In this era of self-assessment, the facts would not have been revealed had investigations into the appellants’ activities not been initiated by the officers of DGCEI. The issue relating to the suppression of facts is dependent on the facts of each case. This being so the extended period for issue of SCN has rightly been invoked under the proviso to sub-section (1) of section 73 of FA 1994. - AT
Extended period of limitation - In this era of self-assessment, the facts would not have been revealed had investigations into the appellants’ activities not been initiated by the officers of DGCEI. The issue relating to the suppression of facts is dependent on the facts of each case. This being so the extended period for issue of SCN has rightly been invoked under the proviso to sub-section (1) of section 73 of FA 1994. - AT
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