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 allowed the petition and quashed the order under section 127(2) effecting centralization of the petitioner-company's PAN to the Central Charge, Bengaluru. The court held the respondent failed to demonstrate necessity or satisfy statutory criteria for transfer: the impugned order relied only on searches of a director and related persons, contained no material linking the petitioner-company to the searched transactions, and did not address the petitioner's objections. The departmental circular was inapplicable because no notices under sections 143(2), 142(1) or 153C were issued by the jurisdictional AO. Assessment records likewise showed no incriminating transactions with the petitioner; jurisdiction therefore remains with Ahmedabad.
The HC allowed the petition and quashed the order under section 127(2) effecting centralization of the petitioner-company's PAN to the Central Charge, Bengaluru. The court held the respondent failed to demonstrate necessity or satisfy statutory criteria for transfer: the impugned order relied only on searches of a director and related persons, contained no material linking the petitioner-company to the searched transactions, and did not address the petitioner's objections. The departmental circular was inapplicable because no notices under sections 143(2), 142(1) or 153C were issued by the jurisdictional AO. Assessment records likewise showed no incriminating transactions with the petitioner; jurisdiction therefore remains with Ahmedabad.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
