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...
Ceasure of income tax settlement commission - restriction to the filing of the application before the Interim Board for Settlement - The Court found that the retrospective legislative changes could not negate the petitioner's vested rights to file a settlement application, particularly when such applications were made before the enactment of the Finance Act, 2021. It was held that the administrative actions and notifications that imposed additional eligibility criteria, not rooted in the Act, were invalid. - The Court quashed the contested notice and notification, directing that the petitioner's application be considered and disposed of in accordance with the law.
Ceasure of income tax settlement commission - restriction to the filing of the application before the Interim Board for Settlement - The Court found that the retrospective legislative changes could not negate the petitioner's vested rights to file a settlement application, particularly when such applications were made before the enactment of the Finance Act, 2021. It was held that the administrative actions and notifications that imposed additional eligibility criteria, not rooted in the Act, were invalid. - The Court quashed the contested notice and notification, directing that the petitioner's application be considered and disposed of in accordance with the law.
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