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...
Special audit u/s 142(2A) - Complexity and Volume of Transactions - Reasonable Opportunity to be Heard - Despite recognizing a breach of natural justice due to the insufficient response time, the High Court ruled that this breach did not cause substantial prejudice to the petitioner. The court emphasized the importance of a prima facie assessment for special audits and supported the Assessing Officer's discretion in such matters. Consequently, the court extended the audit report submission deadline and limited the audit scope, ensuring the petitioner's rights were protected while upholding the Revenue's interests.
Special audit u/s 142(2A) - Complexity and Volume of Transactions - Reasonable Opportunity to be Heard - Despite recognizing a breach of natural justice due to the insufficient response time, the High Court ruled that this breach did not cause substantial prejudice to the petitioner. The court emphasized the importance of a prima facie assessment for special audits and supported the Assessing Officer's discretion in such matters. Consequently, the court extended the audit report submission deadline and limited the audit scope, ensuring the petitioner's rights were protected while upholding the Revenue's interests.
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