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, in a writ petition challenging a SCN seeking finalization of provisional assessments for Bills of Entry dated August 2010 to September 2013, found substantial merit in the importer-petitioner's contentions. Relying on the principle that provisional assessments must be finalized within a reasonable time, approximately five years, the HC held that a delay of 12-15 years is prima facie unreasonable. The Court also accepted that evidence of end-use after 15 years would be impracticable. Holding that a strong prima facie case exists, HC granted ad-interim relief and listed the matter for 8 January 2026.
HC, in a writ petition challenging a SCN seeking finalization of provisional assessments for Bills of Entry dated August 2010 to September 2013, found substantial merit in the importer-petitioner's contentions. Relying on the principle that provisional assessments must be finalized within a reasonable time, approximately five years, the HC held that a delay of 12-15 years is prima facie unreasonable. The Court also accepted that evidence of end-use after 15 years would be impracticable. Holding that a strong prima facie case exists, HC granted ad-interim relief and listed the matter for 8 January 2026.
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