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 Assessment order u/s 147 r.w.s. 144B - Procedural Irregularities - The Court agreed with the petitioner that the show cause notice appeared to be a draft assessment order under Section 144C. Lack of adherence to procedures under Section 144C rendered the proceedings invalid. The matter was remitted back to the authority concerned for a fresh decision, with a directive to strictly adhere to the law and provide the petitioner with a fair opportunity. The Court acknowledged the petitioner's argument regarding the insufficient time provided for response. Consequently, the impugned order was set aside/quashed, and the matter was remitted back to the authority concerned for a fresh decision in accordance with the law.
Validity of Assessment order u/s 147 r.w.s. 144B - Procedural Irregularities - The Court agreed with the petitioner that the show cause notice appeared to be a draft assessment order under Section 144C. Lack of adherence to procedures under Section 144C rendered the proceedings invalid. The matter was remitted back to the authority concerned for a fresh decision, with a directive to strictly adhere to the law and provide the petitioner with a fair opportunity. The Court acknowledged the petitioner's argument regarding the insufficient time provided for response. Consequently, the impugned order was set aside/quashed, and the matter was remitted back to the authority concerned for a fresh decision in accordance with the law.
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