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...
Validity of a notice under section 143(2) was contested on limitation and service grounds: the revised/rectified return filed later was held to relate back to the original return date, so the six month limitation for issuing a notice ran from the original filing and expired before the notice dated 22.09.2019; additionally no notice was served within the statutory period due to change of address/name/email, and because service of the section 143(2) notice is mandatory, the assessment was held void and quashed.
Validity of a notice under section 143(2) was contested on limitation and service grounds: the revised/rectified return filed later was held to relate back to the original return date, so the six month limitation for issuing a notice ran from the original filing and expired before the notice dated 22.09.2019; additionally no notice was served within the statutory period due to change of address/name/email, and because service of the section 143(2) notice is mandatory, the assessment was held void and quashed.
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