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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...
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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 SC permitted petitioners to challenge the assessment order for AY 2022-2023 before CIT (Appeals) with an application for stay and waiver of the 20% deposit requirement under CBDT Office Memoranda dated 29.02.2016 and 31.07.2017. The Court directed that if an appeal is filed within five days, it should not be dismissed on grounds of limitation, considering petitioners had previously approached the High Court. The SC also ordered that no coercive recovery measures be taken for ten days. The Court noted that 30% of the tax demand for AY 2021-2022 had already been recovered through coercive measures. The SLP was disposed of accordingly.
The SC permitted petitioners to challenge the assessment order for AY 2022-2023 before CIT (Appeals) with an application for stay and waiver of the 20% deposit requirement under CBDT Office Memoranda dated 29.02.2016 and 31.07.2017. The Court directed that if an appeal is filed within five days, it should not be dismissed on grounds of limitation, considering petitioners had previously approached the High Court. The SC also ordered that no coercive recovery measures be taken for ten days. The Court noted that 30% of the tax demand for AY 2021-2022 had already been recovered through coercive measures. The SLP was disposed of accordingly.
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