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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...
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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 affirmed the Single Judge's dismissal of the writ petition, holding the appellant's claim untenable because relevant records were destroyed and statutory TDS provisions were inapplicable for significant portions of the claim, rendering issuance of an accountant's certificate in Form 26A practically unenforceable. The court agreed the grievance for FY 2009-10 to 2012-13 did not attract the proviso to Section 201, which took effect on 01.07.2012, and upheld findings of default in non-deduction of tax. The HC also endorsed the Single Judge's view that the petition was time-barred by the decade-long delay. The court noted an ITAT remand for AY 2013-14 but observed no subsequent proceedings were placed on record.
The HC affirmed the Single Judge's dismissal of the writ petition, holding the appellant's claim untenable because relevant records were destroyed and statutory TDS provisions were inapplicable for significant portions of the claim, rendering issuance of an accountant's certificate in Form 26A practically unenforceable. The court agreed the grievance for FY 2009-10 to 2012-13 did not attract the proviso to Section 201, which took effect on 01.07.2012, and upheld findings of default in non-deduction of tax. The HC also endorsed the Single Judge's view that the petition was time-barred by the decade-long delay. The court noted an ITAT remand for AY 2013-14 but observed no subsequent proceedings were placed on record.
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