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 - Re-opening notice u/s 148A(d) - personal hearing refused - the High court concluded that Section 148A(b) does not mandate a personal hearing. The provision requires serving a show cause notice, but the specific words "personal hearing" are not included in the section. - It was noted that while the Income Tax Department may grant a personal hearing at its discretion, refusal to grant such a hearing would not mean that the assessee has been deprived of an opportunity of hearing, as long as there is no specific provision in the statute mandating such a hearing.
Validity of reopening of assessment - Re-opening notice u/s 148A(d) - personal hearing refused - the High court concluded that Section 148A(b) does not mandate a personal hearing. The provision requires serving a show cause notice, but the specific words "personal hearing" are not included in the section. - It was noted that while the Income Tax Department may grant a personal hearing at its discretion, refusal to grant such a hearing would not mean that the assessee has been deprived of an opportunity of hearing, as long as there is no specific provision in the statute mandating such a hearing.
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