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 allowed petitions challenging CBDT's rejection of applications under Section 119(1) of Income Tax Act for condonation of delay in reassessment. Following CG Power precedent, Court found rejection unsustainable both legally and factually. Petitioner voluntarily waived rights to potential tax refunds through authorized memo dated 15.02.2024, demonstrating commitment to fair assessment without financial implications for Revenue. Court confirmed waiver's validity through Power of Attorney dated 22.11.2013, covering refunds post-adjustment of tax liabilities for AY 2002-03 to 2008-09. Petition granted under Article 226, permitting reassessment with condition of no refund claims, ensuring Revenue faces no additional burden.
HC allowed petitions challenging CBDT's rejection of applications under Section 119(1) of Income Tax Act for condonation of delay in reassessment. Following CG Power precedent, Court found rejection unsustainable both legally and factually. Petitioner voluntarily waived rights to potential tax refunds through authorized memo dated 15.02.2024, demonstrating commitment to fair assessment without financial implications for Revenue. Court confirmed waiver's validity through Power of Attorney dated 22.11.2013, covering refunds post-adjustment of tax liabilities for AY 2002-03 to 2008-09. Petition granted under Article 226, permitting reassessment with condition of no refund claims, ensuring Revenue faces no additional burden.
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