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...
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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Where the online return-filing utility prevented a claim of set-off under s.70(2), the Court held that assessees cannot be denied a lawful claim merely because the electronic utility does not permit the prescribed computation, consistent with prior binding precedents. It directed the tax administration to modify the utility to allow the assessee to first set off STCL (STT paid) against STCG (non-STT paid) and only thereafter against STCG (STT paid). Failing timely modification, the authority was ordered to accept and process the revised return for AY 2025-26 in paper form as a valid return under s.139(5), notwithstanding the statutory e-filing mandate. - HC
Where the online return-filing utility prevented a claim of set-off under s.70(2), the Court held that assessees cannot be denied a lawful claim merely because the electronic utility does not permit the prescribed computation, consistent with prior binding precedents. It directed the tax administration to modify the utility to allow the assessee to first set off STCL (STT paid) against STCG (non-STT paid) and only thereafter against STCG (STT paid). Failing timely modification, the authority was ordered to accept and process the revised return for AY 2025-26 in paper form as a valid return under s.139(5), notwithstanding the statutory e-filing mandate. - HC
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