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 examined reassessment proceedings initiated under ss. 148 and 148A (new regime) in light of the SC ruling in Rajeev Bansal and the effect of TOLA and Ashish Agarwal. Applying the "surviving period" doctrine, HC held that, after excluding the periods mandated by SC for deemed stay and for assessee's reply, only one day remained for completion of s.148A(d) proceedings and issuance of a valid s.148 notice, which expired on 9.06.2022. The impugned notice dated 25.07.2022 was therefore held to be time-barred. HC rejected Revenue's contention that non-filing of reply extinguished limitation, and quashed the reassessment notice and consequent proceedings.
HC examined reassessment proceedings initiated under ss. 148 and 148A (new regime) in light of the SC ruling in Rajeev Bansal and the effect of TOLA and Ashish Agarwal. Applying the "surviving period" doctrine, HC held that, after excluding the periods mandated by SC for deemed stay and for assessee's reply, only one day remained for completion of s.148A(d) proceedings and issuance of a valid s.148 notice, which expired on 9.06.2022. The impugned notice dated 25.07.2022 was therefore held to be time-barred. HC rejected Revenue's contention that non-filing of reply extinguished limitation, and quashed the reassessment notice and consequent proceedings.
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