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...
Legality of search u/s 132 scrutinized through Articles 21 and 265 - Doctrine of Proportionality applicable for statutory violations impacting right to privacy. Necessity to examine if search strictly adhered to statutory/constitutional safeguards and resultant impact on admissibility of illegally obtained evidence under Pooran Mal case. Non-communication of reasons for centralization u/s 127 renders transfer void unless assessee acquiesced - Section 292B applicability to be examined. Assessments u/s 153A contingent on seized incriminating material - Sinhgad principles on relevance of seized materials. Individual examination of Section 153C notices mandated instead of generalization. Provisional attachments u/s 281B to be re-examined. Validity of Section 143(2) notices and 143(3) orders open for consideration based on jurisdictional issues. Matter remanded for fresh adjudication.
Legality of search u/s 132 scrutinized through Articles 21 and 265 - Doctrine of Proportionality applicable for statutory violations impacting right to privacy. Necessity to examine if search strictly adhered to statutory/constitutional safeguards and resultant impact on admissibility of illegally obtained evidence under Pooran Mal case. Non-communication of reasons for centralization u/s 127 renders transfer void unless assessee acquiesced - Section 292B applicability to be examined. Assessments u/s 153A contingent on seized incriminating material - Sinhgad principles on relevance of seized materials. Individual examination of Section 153C notices mandated instead of generalization. Provisional attachments u/s 281B to be re-examined. Validity of Section 143(2) notices and 143(3) orders open for consideration based on jurisdictional issues. Matter remanded for fresh adjudication.
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