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...
Assessment completed u/s 144C against a petitioner/Non-Resident Indian - The High Court held that Section 144C is a procedural provision introduced for the benefit of assesses, including NRIs, effective from April 1, 2020. The petitioner's objection to being assessed under Section 144C was deemed meritless as the provision is beneficial and procedural, not substantive. The Court emphasized that the petitioner failed to raise this objection before the assessing authority, rendering it invalid. - Further on the issue of limitation: The High Court noted the provided timeline demonstrated compliance with statutory procedures and extensions granted under TOLA. It concluded that the assessment order was passed within the prescribed time limit, as per the provisions of Section 144C, rendering the petitioner's objection baseless.
Assessment completed u/s 144C against a petitioner/Non-Resident Indian - The High Court held that Section 144C is a procedural provision introduced for the benefit of assesses, including NRIs, effective from April 1, 2020. The petitioner's objection to being assessed under Section 144C was deemed meritless as the provision is beneficial and procedural, not substantive. The Court emphasized that the petitioner failed to raise this objection before the assessing authority, rendering it invalid. - Further on the issue of limitation: The High Court noted the provided timeline demonstrated compliance with statutory procedures and extensions granted under TOLA. It concluded that the assessment order was passed within the prescribed time limit, as per the provisions of Section 144C, rendering the petitioner's objection baseless.
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