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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...
Seeking amendment in the shipping bills - Period of limitation - The Tribunal deemed the 2010 CBEC circular invalid, citing judgments by the Gujarat High Court and the High Court of Bombay. These judgments declared the circular ultra vires and directed authorities to reconsider amendment applications without imposing time limits. Consequently, the Tribunal set aside the communication denying the appellant's request and instructed reconsideration by the Commissioner of Customs within a specified time frame, ensuring a personal hearing for the appellant.
Seeking amendment in the shipping bills - Period of limitation - The Tribunal deemed the 2010 CBEC circular invalid, citing judgments by the Gujarat High Court and the High Court of Bombay. These judgments declared the circular ultra vires and directed authorities to reconsider amendment applications without imposing time limits. Consequently, the Tribunal set aside the communication denying the appellant's request and instructed reconsideration by the Commissioner of Customs within a specified time frame, ensuring a personal hearing for the appellant.
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