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 reassessment proceedings - scope of new regime u/s 148A - The High Court found that the respondents misinterpreted the Supreme Court's directive in Union of India & Ors. vs. Ashish Agarwal. The directive was not to reopen completed assessments but to treat notices issued post-April 1, 2021, under the unamended provisions as if they were issued under the new provisions of Section 148A. - The Court underscored that the procedural safeguards introduced by the Finance Act, 2021, through Section 148A were aimed at protecting the assessee's rights. - Consequently, the Court quashed the impugned SCN issued u/s 148A(b), the order u/s 148A(d), and the notice u/s 148.
Validity of reassessment proceedings - scope of new regime u/s 148A - The High Court found that the respondents misinterpreted the Supreme Court's directive in Union of India & Ors. vs. Ashish Agarwal. The directive was not to reopen completed assessments but to treat notices issued post-April 1, 2021, under the unamended provisions as if they were issued under the new provisions of Section 148A. - The Court underscored that the procedural safeguards introduced by the Finance Act, 2021, through Section 148A were aimed at protecting the assessee's rights. - Consequently, the Court quashed the impugned SCN issued u/s 148A(b), the order u/s 148A(d), and the notice u/s 148.
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