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...
Whether assessing officers must verify claimed TDS credits and whether courts may direct automated software changes to prevent demands: the Court held that the Assessing Officer must examine factual records before waiving liability for undeposited TDS, since technology aids processing but cannot replace adjudication; therefore verification and, where necessary, show-cause procedures remain essential - outcome: AO's verification duty affirmed. Whether High Court could order departmental software modifications and automatic non-raising of demands: the Court held such directions intrude on adjudicatory functions and risk ignoring genuine demands - outcome: directions to modify the software were set aside. - SC
Whether assessing officers must verify claimed TDS credits and whether courts may direct automated software changes to prevent demands: the Court held that the Assessing Officer must examine factual records before waiving liability for undeposited TDS, since technology aids processing but cannot replace adjudication; therefore verification and, where necessary, show-cause procedures remain essential - outcome: AO's verification duty affirmed. Whether High Court could order departmental software modifications and automatic non-raising of demands: the Court held such directions intrude on adjudicatory functions and risk ignoring genuine demands - outcome: directions to modify the software were set aside. - SC
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