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 TPO order u/s 92CA - Period of limitation u/s 153(3) - The High court found the final order of assessment dated 13 February 2023 was indeed passed beyond the statutory time limit and was thus liable to be set aside. It also noted that the adjustments made against refunds for earlier assessment years were improper, as there was no valid demand for A.Y. 2011-12 at the time of those adjustments.
Validity of TPO order u/s 92CA - Period of limitation u/s 153(3) - The High court found the final order of assessment dated 13 February 2023 was indeed passed beyond the statutory time limit and was thus liable to be set aside. It also noted that the adjustments made against refunds for earlier assessment years were improper, as there was no valid demand for A.Y. 2011-12 at the time of those adjustments.
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