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...
Challenge to service of the show cause notice (SCN) on the ground that it was uploaded only in the "Additional Notices" tab was rejected, as the portal changes after 16 January 2024 made that tab visible and accessible, and the SCN issued on 17 May 2024 was shown to be available there. However, the adjudication order was held vitiated for breach of natural justice because it was passed without considering the taxpayer's submissions and contentions; additionally, the impugned time-extension notifications were noted to be under challenge before superior judicial forums. The order was set aside, time was granted to file reply to the SCN up to 30 September 2025, and a personal hearing was directed thereafter. - HC
Challenge to service of the show cause notice (SCN) on the ground that it was uploaded only in the "Additional Notices" tab was rejected, as the portal changes after 16 January 2024 made that tab visible and accessible, and the SCN issued on 17 May 2024 was shown to be available there. However, the adjudication order was held vitiated for breach of natural justice because it was passed without considering the taxpayer's submissions and contentions; additionally, the impugned time-extension notifications were noted to be under challenge before superior judicial forums. The order was set aside, time was granted to file reply to the SCN up to 30 September 2025, and a personal hearing was directed thereafter. - HC
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