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...
Arguable jurisdictional defects were identified in reassessment proceedings: the notice under Section 148 was challenged on the ground that only a Faceless Assessing Officer may issue such notices post 29 March 2022, rendering notices issued by the Jurisdictional Assessing Officer prima facie void; this ground was held sufficient to invoke writ jurisdiction. Separately, the notice gave only thirty days to file a return, whereas a statutory minimum three month period was asserted, which likewise raised a substantial jurisdictional objection. On these bases the High Court entertained the writ, issued rule, and granted interim relief restraining reassessment, demand and penalty notices pending final disposal.
Arguable jurisdictional defects were identified in reassessment proceedings: the notice under Section 148 was challenged on the ground that only a Faceless Assessing Officer may issue such notices post 29 March 2022, rendering notices issued by the Jurisdictional Assessing Officer prima facie void; this ground was held sufficient to invoke writ jurisdiction. Separately, the notice gave only thirty days to file a return, whereas a statutory minimum three month period was asserted, which likewise raised a substantial jurisdictional objection. On these bases the High Court entertained the writ, issued rule, and granted interim relief restraining reassessment, demand and penalty notices pending final disposal.
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