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 - scope of old unamended law and new inserted section 148A - The High court held that notices issued under the newly inserted Section 148A(b), treating them as if issued under the old Section 148 post-April 1, 2021, for assessment years 2013-14 and 2014-15 were invalid. The court found that the extension of time for issuing notices under the old Section 148, based on TOLA and subsequent CBDT notifications, was unauthorized after the old provisions were superseded by the Finance Act, 2021, without any saving clause for the old reassessment provisions.
Validity of reopening of assessment - scope of old unamended law and new inserted section 148A - The High court held that notices issued under the newly inserted Section 148A(b), treating them as if issued under the old Section 148 post-April 1, 2021, for assessment years 2013-14 and 2014-15 were invalid. The court found that the extension of time for issuing notices under the old Section 148, based on TOLA and subsequent CBDT notifications, was unauthorized after the old provisions were superseded by the Finance Act, 2021, without any saving clause for the old reassessment provisions.
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