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 affirmed tax authority's adjustment of AY 2010-11 refund against pre-existing tax liabilities of corporate debtor. Resolution applicant's claim to refund rejected on dual grounds: first, the adjustment effectively reduced tax dues already considered in approved resolution plan; second, resolution applicant's rights commenced only from plan approval date (November 7, 2017), precluding claims to pre-resolution period tax refunds. Court determined resolution applicant could not assert rights over tax assessments and resultant refunds from AY 2010-11, as these predated their assumption of corporate debtor's management. Challenge to adjustment procedure dismissed despite notice argument.
HC affirmed tax authority's adjustment of AY 2010-11 refund against pre-existing tax liabilities of corporate debtor. Resolution applicant's claim to refund rejected on dual grounds: first, the adjustment effectively reduced tax dues already considered in approved resolution plan; second, resolution applicant's rights commenced only from plan approval date (November 7, 2017), precluding claims to pre-resolution period tax refunds. Court determined resolution applicant could not assert rights over tax assessments and resultant refunds from AY 2010-11, as these predated their assumption of corporate debtor's management. Challenge to adjustment procedure dismissed despite notice argument.
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