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...
No time limit prescribed u/s 279(2) of Income Tax Act for filing compounding application. CBDT circular fixing 36-month limitation period held contrary to the Act and impermissible. Judgment in Jayshree's case applied, holding CBDT cannot issue circular contrary to the object of statutory provisions. Once an offence is compoundable under the Act, right cannot be taken away by prescribing time limit through circular. Impugned order rejecting compounding application set aside.
No time limit prescribed u/s 279(2) of Income Tax Act for filing compounding application. CBDT circular fixing 36-month limitation period held contrary to the Act and impermissible. Judgment in Jayshree's case applied, holding CBDT cannot issue circular contrary to the object of statutory provisions. Once an offence is compoundable under the Act, right cannot be taken away by prescribing time limit through circular. Impugned order rejecting compounding application set aside.
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