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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...
Refund of EDD - Period of limitation - Appellant unaware of finalisation of bills of entry - The Appellate Tribunal notes that neither the original authority nor subsequent communications mentioned the actual date of finalization of the bills of entry. This absence of crucial information places the burden on the revenue to prove the date of communication of the Order in Original. Due to the lack of evidence from the revenue establishing the actual date of communication of the Order in Original, the Tribunal finds no grounds to support the claim that the appellant's application for refund was time-barred.
Refund of EDD - Period of limitation - Appellant unaware of finalisation of bills of entry - The Appellate Tribunal notes that neither the original authority nor subsequent communications mentioned the actual date of finalization of the bills of entry. This absence of crucial information places the burden on the revenue to prove the date of communication of the Order in Original. Due to the lack of evidence from the revenue establishing the actual date of communication of the Order in Original, the Tribunal finds no grounds to support the claim that the appellant's application for refund was time-barred.
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