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...
Settlement applications filed between 01.02.2021 and 31.03.2021, prior to amendment of Section 245C(5) of the Act, are maintainable before the Interim Board for Settlement. Retrospective amendment cannot invalidate applications filed when no prohibitory statute existed. Petitioners had vested right to file applications before 31.03.2021 when amendment took effect. CBDT extending last date to 30.09.2021 for eligible cases as on 31.01.2021 cannot override non-existent Section 245C(5). Applications filed after 01.02.2021 but before 31.03.2021 cannot be invalid. Section 245C(5) rightly read down to apply from 01.04.2021 when assented. Petitions allowed, impugned orders set aside, applications deemed pending for Interim Board's consideration if otherwise eligible. Consequential actions by Assessing Officers quashed. Matter remanded to Interim Board for deciding applications on merits.
Settlement applications filed between 01.02.2021 and 31.03.2021, prior to amendment of Section 245C(5) of the Act, are maintainable before the Interim Board for Settlement. Retrospective amendment cannot invalidate applications filed when no prohibitory statute existed. Petitioners had vested right to file applications before 31.03.2021 when amendment took effect. CBDT extending last date to 30.09.2021 for eligible cases as on 31.01.2021 cannot override non-existent Section 245C(5). Applications filed after 01.02.2021 but before 31.03.2021 cannot be invalid. Section 245C(5) rightly read down to apply from 01.04.2021 when assented. Petitions allowed, impugned orders set aside, applications deemed pending for Interim Board's consideration if otherwise eligible. Consequential actions by Assessing Officers quashed. Matter remanded to Interim Board for deciding applications on merits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
