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...
Regulation 20(7) of CBLR 2013 and Regulation 17(7) of Customs Broker License Regulation 2018 mandate issuing show cause notice within 90 days from receipt of offence report, but failure to adhere is directory, not mandatory. Department unduly delayed issuing show cause notice and finalizing Order-in-Original after receiving Enquiry Report. Show cause notices to importers did not mention appellant's role in alleged clandestine activities. Appellant operated with minimal staff during COVID, lacking direct control over employee's Chennai transactions. No direct involvement of appellant established, but some negligence cannot be ruled out. CHA License revocation set aside, directed to restore immediately. Penalty reduced to Rs. 5,000/- considering appellant's over one-year business loss. Appeal partly allowed.
Regulation 20(7) of CBLR 2013 and Regulation 17(7) of Customs Broker License Regulation 2018 mandate issuing show cause notice within 90 days from receipt of offence report, but failure to adhere is directory, not mandatory. Department unduly delayed issuing show cause notice and finalizing Order-in-Original after receiving Enquiry Report. Show cause notices to importers did not mention appellant's role in alleged clandestine activities. Appellant operated with minimal staff during COVID, lacking direct control over employee's Chennai transactions. No direct involvement of appellant established, but some negligence cannot be ruled out. CHA License revocation set aside, directed to restore immediately. Penalty reduced to Rs. 5,000/- considering appellant's over one-year business loss. Appeal partly allowed.
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