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...
Section 245 of the Income Tax Act empowers the Assessing Officer to adjust refund against outstanding tax demand and withhold refund where assessment or reassessment is pending. The Finance Act, 2023 integrated sections 241A and 245. Section 245(2) allows withholding refund if grant adversely affects revenue, with reasons recorded and approval. The amendment proposes retaining the phrase "for reasons recorded in writing" and extending the withholding period to 60 days from assessment date. Consequential amendment in section 244A disallows additional interest during withholding period. The amendment takes effect from October 1, 2024.
Section 245 of the Income Tax Act empowers the Assessing Officer to adjust refund against outstanding tax demand and withhold refund where assessment or reassessment is pending. The Finance Act, 2023 integrated sections 241A and 245. Section 245(2) allows withholding refund if grant adversely affects revenue, with reasons recorded and approval. The amendment proposes retaining the phrase "for reasons recorded in writing" and extending the withholding period to 60 days from assessment date. Consequential amendment in section 244A disallows additional interest during withholding period. The amendment takes effect from October 1, 2024.
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