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...
The court examined the validity of search and seizure u/s 132, focusing on the scope of Revenue's power and the "reasons to believe" requirement. It held that the 'satisfaction note' lacked material relating to discrete inquiry and information gathered, failing to reflect the basis for believing the petitioners would not disclose possession of money. The court distinguished "reasons to believe" from "reasons to suspect," emphasizing that the competent authority must have cogent incriminating material prior to seizure to record satisfaction. Mere suspicion or unexplained possession of amount cannot justify action u/s 132. Consequently, the impugned search and seizure was set aside, and the seized amount ordered to be returned, without precluding further lawful proceedings against the petitioners.
The court examined the validity of search and seizure u/s 132, focusing on the scope of Revenue's power and the "reasons to believe" requirement. It held that the 'satisfaction note' lacked material relating to discrete inquiry and information gathered, failing to reflect the basis for believing the petitioners would not disclose possession of money. The court distinguished "reasons to believe" from "reasons to suspect," emphasizing that the competent authority must have cogent incriminating material prior to seizure to record satisfaction. Mere suspicion or unexplained possession of amount cannot justify action u/s 132. Consequently, the impugned search and seizure was set aside, and the seized amount ordered to be returned, without precluding further lawful proceedings against the petitioners.
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