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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...
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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...
Abeyance of limitation applies where a rectification application under the GST statute was pending; the time spent pursuing rectification is excluded and the appeal is maintainable despite delay, the Court applying the principle of bona fide pursuit before a wrong forum and directing the appellate authority to decide on merits. Because the petitioner deposited 10% in the leading matter and 25% in the connected matter, the appeals are to be treated as not barred by delay, and the appellate authority must decide them on merits within two months. Writ petitions disposed accordingly.
Abeyance of limitation applies where a rectification application under the GST statute was pending; the time spent pursuing rectification is excluded and the appeal is maintainable despite delay, the Court applying the principle of bona fide pursuit before a wrong forum and directing the appellate authority to decide on merits. Because the petitioner deposited 10% in the leading matter and 25% in the connected matter, the appeals are to be treated as not barred by delay, and the appellate authority must decide them on merits within two months. Writ petitions disposed accordingly.
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