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...
Levy of penalty u/s 271C - Period of limitation - Failure to deduct TDS - The Appellate Tribunal analyzed the facts and submissions of both parties. It was observed that the assessee had not deducted TDS as reported by the Tax Auditor, leading to a reference made by the Assessing Officer (AO) to the Joint Commissioner of Income Tax (JCIT). The Tribunal delved into the interpretation of the limitation period under Section 275(1)(c) of the Act. It considered the date of completion of quantum proceedings and the initiation of penalty proceedings. Referring to a relevant judicial precedent, the Tribunal concluded that the penalty order was indeed barred by limitation.
Levy of penalty u/s 271C - Period of limitation - Failure to deduct TDS - The Appellate Tribunal analyzed the facts and submissions of both parties. It was observed that the assessee had not deducted TDS as reported by the Tax Auditor, leading to a reference made by the Assessing Officer (AO) to the Joint Commissioner of Income Tax (JCIT). The Tribunal delved into the interpretation of the limitation period under Section 275(1)(c) of the Act. It considered the date of completion of quantum proceedings and the initiation of penalty proceedings. Referring to a relevant judicial precedent, the Tribunal concluded that the penalty order was indeed barred by limitation.
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