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 the Assessing Officer could pass an order giving effect to DRP directions after expiry of the one-month period mandated by section 144C(13). The court held that section 144C(13) imposes a strict, mandatory timeline, and statutory requirements must be complied with in the prescribed manner; treating the time limit as directory would negate the provision's mandatory character. Since the one-month period had already lapsed, the pending proceedings to give effect to the DRP directions, including the transfer pricing addition, were barred by limitation and could not be continued under section 144C(13). - HC
The dominant issue was whether the Assessing Officer could pass an order giving effect to DRP directions after expiry of the one-month period mandated by section 144C(13). The court held that section 144C(13) imposes a strict, mandatory timeline, and statutory requirements must be complied with in the prescribed manner; treating the time limit as directory would negate the provision's mandatory character. Since the one-month period had already lapsed, the pending proceedings to give effect to the DRP directions, including the transfer pricing addition, were barred by limitation and could not be continued under section 144C(13). - HC
Note: It is a system-generated summary and is for quick reference only.