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 held that notices under s.148 issued by jurisdictional Assessing Officer remain valid despite faceless assessment requirements, as traditional and faceless mechanisms are meant to work complementarily. The Court rejected challenges to AO's jurisdiction, clarifying that distribution of functions between jurisdictional AO and National Faceless Assessment Centre is concurrent. However, approvals granted by Joint Commissioner post April 1, 2021, were deemed invalid. AOs were directed to evaluate individual show cause notices considering precedents from T.K.S. Builders, Abhinav Jindal, and Naveen Kumar Gupta cases regarding sanction under s.151 and reassessment procedures. Assessment of limitation periods must follow Rajeev Bansal and Ram Balram judgments. AOs must issue reasoned orders determining validity of reassessment notices, with petitioners retaining right to challenge adverse decisions.
HC held that notices under s.148 issued by jurisdictional Assessing Officer remain valid despite faceless assessment requirements, as traditional and faceless mechanisms are meant to work complementarily. The Court rejected challenges to AO's jurisdiction, clarifying that distribution of functions between jurisdictional AO and National Faceless Assessment Centre is concurrent. However, approvals granted by Joint Commissioner post April 1, 2021, were deemed invalid. AOs were directed to evaluate individual show cause notices considering precedents from T.K.S. Builders, Abhinav Jindal, and Naveen Kumar Gupta cases regarding sanction under s.151 and reassessment procedures. Assessment of limitation periods must follow Rajeev Bansal and Ram Balram judgments. AOs must issue reasoned orders determining validity of reassessment notices, with petitioners retaining right to challenge adverse decisions.
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