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 CBDT's order imposing additional eligibility condition requiring assessees to satisfy requirements as on 31.03.2021 was ultra vires Section 119(2)(b) powers. Court ruled that assessees receiving notices under Sections 153A/153C between 31.03.2021 and 30.09.2021 could maintain settlement applications before Interim Board for Settlement if filed by 30.09.2021. Single Judge's interpretation that search proceedings under Section 132 fall within 'case' definition was set aside. Revenue's writ appeals allowed partially. Court directed Interim Board to consider on merits settlement applications filed by assessees who received post-31.03.2021 notices, provided applications were submitted before 30.09.2021 deadline.
HC held that CBDT's order imposing additional eligibility condition requiring assessees to satisfy requirements as on 31.03.2021 was ultra vires Section 119(2)(b) powers. Court ruled that assessees receiving notices under Sections 153A/153C between 31.03.2021 and 30.09.2021 could maintain settlement applications before Interim Board for Settlement if filed by 30.09.2021. Single Judge's interpretation that search proceedings under Section 132 fall within 'case' definition was set aside. Revenue's writ appeals allowed partially. Court directed Interim Board to consider on merits settlement applications filed by assessees who received post-31.03.2021 notices, provided applications were submitted before 30.09.2021 deadline.
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