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 - grievance raised that the objections raised were not specifically dealt - Procedure prescribed u/s 148A followed or not? - The Central Board of Direct Taxes (CBDT) after the decision of Supreme Court in Ashish Agarwal issued guidelines for issuance of notice u/s 148 - The High court found that the impugned order did not adhere to the prescribed procedures u/s 148A of the Act and the CBDT guidelines. The order was quashed, and the matter was remitted back to the respondent for further proceedings in accordance with the law. - Consequently, the HC remanded the matter back to proceed with notice u/s 148-A(b) in accordance with law.
Validity of reopening of assessment - grievance raised that the objections raised were not specifically dealt - Procedure prescribed u/s 148A followed or not? - The Central Board of Direct Taxes (CBDT) after the decision of Supreme Court in Ashish Agarwal issued guidelines for issuance of notice u/s 148 - The High court found that the impugned order did not adhere to the prescribed procedures u/s 148A of the Act and the CBDT guidelines. The order was quashed, and the matter was remitted back to the respondent for further proceedings in accordance with the law. - Consequently, the HC remanded the matter back to proceed with notice u/s 148-A(b) in accordance with law.
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