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 reassessment initiation under the post-01.04.2021 regime was barred by limitation where an earlier notice issued on 30.06.2021 under the erstwhile Section 148 was deemed to be under Section 148A(b). Applying the legal fiction in Ashish Agarwal and the clarification in Rajeev Bansal, the court held that limitation had to be tested by the surviving time under Section 149 read with TOLA, and that a fresh Section 148 notice under the new regime could be issued only if limitation under the old regime had not already expired. Since TOLA extended the old-regime six-year period up to 30.06.2021 and the escaped income exceeded Rs. 50 lakh, the 29.07.2022 notice was within time and had valid Section 151 approval; the writ was dismissed. - HC
The dominant issue was whether reassessment initiation under the post-01.04.2021 regime was barred by limitation where an earlier notice issued on 30.06.2021 under the erstwhile Section 148 was deemed to be under Section 148A(b). Applying the legal fiction in Ashish Agarwal and the clarification in Rajeev Bansal, the court held that limitation had to be tested by the surviving time under Section 149 read with TOLA, and that a fresh Section 148 notice under the new regime could be issued only if limitation under the old regime had not already expired. Since TOLA extended the old-regime six-year period up to 30.06.2021 and the escaped income exceeded Rs. 50 lakh, the 29.07.2022 notice was within time and had valid Section 151 approval; the writ was dismissed. - HC
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