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...
The HC quashed a tax revision notice issued under section 263 against a dissolved company. The court held that the approved Resolution Plan had explicitly extinguished all tax liabilities of the Corporate Debtor for periods prior to NCLT approval on 12.10.2023. Relying on Essar and Edelweiss Supreme Court precedents, the court determined that once the Resolution Plan extinguished all tax liabilities, there was no legal basis for authorities to issue revision notices for Assessment Year 2015-16. The petition was allowed and the impugned notice dated 13.01.2025 was set aside as the question of its merits had become academic.
The HC quashed a tax revision notice issued under section 263 against a dissolved company. The court held that the approved Resolution Plan had explicitly extinguished all tax liabilities of the Corporate Debtor for periods prior to NCLT approval on 12.10.2023. Relying on Essar and Edelweiss Supreme Court precedents, the court determined that once the Resolution Plan extinguished all tax liabilities, there was no legal basis for authorities to issue revision notices for Assessment Year 2015-16. The petition was allowed and the impugned notice dated 13.01.2025 was set aside as the question of its merits had become academic.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
