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...
Failure to issue Form-4 under the Income Declaration Scheme, 2016 despite payment of tax resulted in the disclosed income being again assessed in A.Y. 2017-18, causing double taxation. The court held that the self-assessment tax paid pursuant to the deeming fiction under Section 197(b) (treating the declaration as rejected for non-payment of the third instalment) was inextricably linked to the same undisclosed income and, consistent with CBDT Circular No. 25/2016 and the beneficial object of the revival provisions, had to be credited as payment towards the Scheme. Authorities were directed to treat the self-assessment tax as the third instalment, issue Form-4, and modify the A.Y. 2017-18 assessment by excluding the disclosed income and recomputing demand accordingly. - HC
Failure to issue Form-4 under the Income Declaration Scheme, 2016 despite payment of tax resulted in the disclosed income being again assessed in A.Y. 2017-18, causing double taxation. The court held that the self-assessment tax paid pursuant to the deeming fiction under Section 197(b) (treating the declaration as rejected for non-payment of the third instalment) was inextricably linked to the same undisclosed income and, consistent with CBDT Circular No. 25/2016 and the beneficial object of the revival provisions, had to be credited as payment towards the Scheme. Authorities were directed to treat the self-assessment tax as the third instalment, issue Form-4, and modify the A.Y. 2017-18 assessment by excluding the disclosed income and recomputing demand accordingly. - HC
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