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...
The dominant issue was whether an assessment order passed pursuant to search-related proceedings could be sustained as being within limitation by invoking section 153(6)(i) of the Income-tax Act. The court held that, after the interim stay when only eleven days remained, limitation could at best stand extended by sixty days from the relevant Supreme Court decision date (or even from the date of its receipt by the assessing officer), which still rendered the order dated 30.04.2024 time-barred. It further held that section 153(6)(i) cannot be applied in isolation and, read with section 153, pertains to general assessments under sections 143/144, not section 153C search assessments with distinct statutory timelines. The assessment order was quashed and the writ petition was allowed. - HC
The dominant issue was whether an assessment order passed pursuant to search-related proceedings could be sustained as being within limitation by invoking section 153(6)(i) of the Income-tax Act. The court held that, after the interim stay when only eleven days remained, limitation could at best stand extended by sixty days from the relevant Supreme Court decision date (or even from the date of its receipt by the assessing officer), which still rendered the order dated 30.04.2024 time-barred. It further held that section 153(6)(i) cannot be applied in isolation and, read with section 153, pertains to general assessments under sections 143/144, not section 153C search assessments with distinct statutory timelines. The assessment order was quashed and the writ petition was allowed. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
