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...
Penalty imposed u/s 271B for delay in filing the return. The key points are: The assessee failed to get accounts audited as per Section 44AB. The penalty order u/s 271B was passed on 05.07.2021, and the assessee filed an appeal before the CIT(A)/NFAC on 22.01.2022, resulting in a delay of 171 days. Following the Tribunal's order in the assessee's quantum proceedings for the same assessment year, the issue was restored to the CIT(A)/NFAC to condone the delay in filing the appeal and decide the matter on merits after providing an opportunity of being heard to the assessee. The grounds raised by the assessee were allowed for statistical purposes.
Penalty imposed u/s 271B for delay in filing the return. The key points are: The assessee failed to get accounts audited as per Section 44AB. The penalty order u/s 271B was passed on 05.07.2021, and the assessee filed an appeal before the CIT(A)/NFAC on 22.01.2022, resulting in a delay of 171 days. Following the Tribunal's order in the assessee's quantum proceedings for the same assessment year, the issue was restored to the CIT(A)/NFAC to condone the delay in filing the appeal and decide the matter on merits after providing an opportunity of being heard to the assessee. The grounds raised by the assessee were allowed for statistical purposes.
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