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 Explanation to Section 149 and Explanation 4 to Section 147, introduced by Finance Act, 2012, clarify retrospective applicability for assessment years beginning on or before 1 April 2012. The use of word "any" in the explanation is not restrictive. The court noted that previous judicial interpretations in Brahm Datt and Jyoti Traders may require reconsideration by a larger bench. The matter was directed to be listed for constitution of a larger bench to comprehensively examine the legislative intent behind the amendments to income tax assessment provisions.
HC held that Explanation to Section 149 and Explanation 4 to Section 147, introduced by Finance Act, 2012, clarify retrospective applicability for assessment years beginning on or before 1 April 2012. The use of word "any" in the explanation is not restrictive. The court noted that previous judicial interpretations in Brahm Datt and Jyoti Traders may require reconsideration by a larger bench. The matter was directed to be listed for constitution of a larger bench to comprehensively examine the legislative intent behind the amendments to income tax assessment provisions.
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