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...
Penalty u/s 271C - failure to deduct TDS u/s 194C on External Development Charges - The High court noted that the applicability of Section 194C had been explicitly raised in counter-affidavits, providing sufficient notice to the petitioners. Therefore, the court declined to interfere with the show-cause notices at this stage. - Regarding the treatment of the petitioners as an assessee-in-default and the imposition of penalties u/s 221 and 271C of the Act, the court observed that such penalties were not inevitable consequences of default. - In this case, the court found that there was a genuine and bona fide legal issue surrounding the applicability of Section 194C to the supplementary commission. Therefore, the court quashed the penalty proceedings under Section 271C.
Penalty u/s 271C - failure to deduct TDS u/s 194C on External Development Charges - The High court noted that the applicability of Section 194C had been explicitly raised in counter-affidavits, providing sufficient notice to the petitioners. Therefore, the court declined to interfere with the show-cause notices at this stage. - Regarding the treatment of the petitioners as an assessee-in-default and the imposition of penalties u/s 221 and 271C of the Act, the court observed that such penalties were not inevitable consequences of default. - In this case, the court found that there was a genuine and bona fide legal issue surrounding the applicability of Section 194C to the supplementary commission. Therefore, the court quashed the penalty proceedings under Section 271C.
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