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...
Cancellation of GST registration was held vitiated for breach of natural justice where the taxpayer's revocation application remained undecided beyond the statutory time and the department failed to disclose its status, undermining the cancellation process; consequently, the show-cause notice, cancellation order, and appellate dismissal were set aside. Further, the department's stance was internally inconsistent: cancellation proceeded on the premise of no business activity at the premises, yet best-judgment assessments under section 63 for multiple prior years alleged continued business based on GSTR-2A; this contradiction rendered the impugned cancellation-related actions unsustainable. The separate section 63 assessment orders were left to be challenged through statutory appeals. - HC
Cancellation of GST registration was held vitiated for breach of natural justice where the taxpayer's revocation application remained undecided beyond the statutory time and the department failed to disclose its status, undermining the cancellation process; consequently, the show-cause notice, cancellation order, and appellate dismissal were set aside. Further, the department's stance was internally inconsistent: cancellation proceeded on the premise of no business activity at the premises, yet best-judgment assessments under section 63 for multiple prior years alleged continued business based on GSTR-2A; this contradiction rendered the impugned cancellation-related actions unsustainable. The separate section 63 assessment orders were left to be challenged through statutory appeals. - HC
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