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...
HC quashed and set aside order dated 24 January 2024 rejecting condonation application for delayed income tax return filing. Court found Additional CIT (OSD) (OT & WT) lacked authority to issue orders under s.119(2)(b) of Income Tax Act, as this power vests with CBDT. While CBDT may allocate work among members, no evidence demonstrated valid delegation to Additional CIT. Matter remanded to CBDT or authorized member for fresh consideration with directions to hear petitioner and issue reasoned order within 3 months. Ruling clarified procedural requirements for exercising powers under s.119(2)(b), emphasizing proper authority and delegation channels.
HC quashed and set aside order dated 24 January 2024 rejecting condonation application for delayed income tax return filing. Court found Additional CIT (OSD) (OT & WT) lacked authority to issue orders under s.119(2)(b) of Income Tax Act, as this power vests with CBDT. While CBDT may allocate work among members, no evidence demonstrated valid delegation to Additional CIT. Matter remanded to CBDT or authorized member for fresh consideration with directions to hear petitioner and issue reasoned order within 3 months. Ruling clarified procedural requirements for exercising powers under s.119(2)(b), emphasizing proper authority and delegation channels.
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