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...
Rule 12(3) made e-filing of returns by companies mandatory with effect from 14.05.2007, and neither s.139 nor the CBDT circulars preserved any general option for companies to file manual returns for AY 2008-09. The limited relaxations cited (e.g., Settlement Commission-related difficulty and non-resident agents) did not apply to a company assessee. Given the statutory rule framework and the assessee's prior e-filing history, the manual return filed within time could not cure the belated electronic filing, and the view that CBDT circulars impermissibly overrode the statute was rejected; consequently, the denial of deduction u/s 80-IC on account of belated return was sustained. - HC
Rule 12(3) made e-filing of returns by companies mandatory with effect from 14.05.2007, and neither s.139 nor the CBDT circulars preserved any general option for companies to file manual returns for AY 2008-09. The limited relaxations cited (e.g., Settlement Commission-related difficulty and non-resident agents) did not apply to a company assessee. Given the statutory rule framework and the assessee's prior e-filing history, the manual return filed within time could not cure the belated electronic filing, and the view that CBDT circulars impermissibly overrode the statute was rejected; consequently, the denial of deduction u/s 80-IC on account of belated return was sustained. - HC
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