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...
The High Court addressed the issue of penalty levy and rejection of Amnesty Scheme benefit. The petitioner sought penalty waiver under the Scheme after paying tax and interest before the assessment order. The court held that the Amnesty Scheme allows for interest and penalty waiver, but no refund if already paid. The petitioner believed penalty payment was unnecessary due to prior tax and interest payment. The authorities misinterpreted the Scheme, leading to rejection. Relying on precedent and case facts, the court found the rejection erroneous. The petitioner was granted penalty waiver, and the impugned communication and attachment order were quashed. The petition was allowed.
The High Court addressed the issue of penalty levy and rejection of Amnesty Scheme benefit. The petitioner sought penalty waiver under the Scheme after paying tax and interest before the assessment order. The court held that the Amnesty Scheme allows for interest and penalty waiver, but no refund if already paid. The petitioner believed penalty payment was unnecessary due to prior tax and interest payment. The authorities misinterpreted the Scheme, leading to rejection. Relying on precedent and case facts, the court found the rejection erroneous. The petitioner was granted penalty waiver, and the impugned communication and attachment order were quashed. The petition was allowed.
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