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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...
Non-disclosure of foreign assets and false statements made by the petitioners, office bearers of certain business establishments of two British Companies, u/s 50 of the Black Money Act. The Act came into force on 01-07-2015, and the petitioners were summoned and assessed u/s 10 in 2018. The High Court held that criminal law cannot be set into motion against the petitioners as it violates Article 20 of the Constitution, which is a fundamental right and supersedes any statutory provision. The rigour of the Act's provisions fails to pass the muster of Article 20, leading to the obliteration of the crime against the petitioners. The impugned order regarding criminal liability u/s 72(c) of the Act remains stayed.
Non-disclosure of foreign assets and false statements made by the petitioners, office bearers of certain business establishments of two British Companies, u/s 50 of the Black Money Act. The Act came into force on 01-07-2015, and the petitioners were summoned and assessed u/s 10 in 2018. The High Court held that criminal law cannot be set into motion against the petitioners as it violates Article 20 of the Constitution, which is a fundamental right and supersedes any statutory provision. The rigour of the Act's provisions fails to pass the muster of Article 20, leading to the obliteration of the crime against the petitioners. The impugned order regarding criminal liability u/s 72(c) of the Act remains stayed.
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