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 holds that reassessment notices issued between 1 Apr 2021 and 30 Jun 2021 under the pre-existing regime are to be treated as deemed show-cause notices under the new reassessment law, with the residual limitation computed up to 30 Jun 2021 under TOLA. For valid exercise of jurisdiction under s.148 of the new regime, the AO must issue notices within the surviving period read with s.149(1) and obtain prior approval under s.151; non-compliance renders the notice and consequential assessment void. Consequently, the s.148A(d) order dated 25.07.2022, the s.148 notice dated 25.07.2022 and the assessment order purportedly passed on 22.05.2023 are set aside.
The HC holds that reassessment notices issued between 1 Apr 2021 and 30 Jun 2021 under the pre-existing regime are to be treated as deemed show-cause notices under the new reassessment law, with the residual limitation computed up to 30 Jun 2021 under TOLA. For valid exercise of jurisdiction under s.148 of the new regime, the AO must issue notices within the surviving period read with s.149(1) and obtain prior approval under s.151; non-compliance renders the notice and consequential assessment void. Consequently, the s.148A(d) order dated 25.07.2022, the s.148 notice dated 25.07.2022 and the assessment order purportedly passed on 22.05.2023 are set aside.
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