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...
Section 201(3) limitation begins from the end of the financial year in which each quarterly TDS statement is filed, making each quarterly filing an independent trigger for the two-year limitation period; Rule 31A's quarterly filing requirement confirms that each quarter is a distinct compliance event and precludes an annual or cumulative computation of limitation. The statutory language and TDS scheme require strict construction of limitation, so earlier quarters filed in one financial year are time-barred while a quarter filed in the subsequent financial year remains within limitation; the Tribunal's conclusion dismissing the appeal as to limitation was affirmed.
Section 201(3) limitation begins from the end of the financial year in which each quarterly TDS statement is filed, making each quarterly filing an independent trigger for the two-year limitation period; Rule 31A's quarterly filing requirement confirms that each quarter is a distinct compliance event and precludes an annual or cumulative computation of limitation. The statutory language and TDS scheme require strict construction of limitation, so earlier quarters filed in one financial year are time-barred while a quarter filed in the subsequent financial year remains within limitation; the Tribunal's conclusion dismissing the appeal as to limitation was affirmed.
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