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...
Interplay between limitation under section 144C(13) and section 153 was examined, with the tribunal considering the Madras High Court view that the two provisions are inter dependent and overlapping for matters under section 92CA; the tribunal concluded the timeline for passing final assessment orders must be determined with reference to section 144C read with section 153 and found the final assessment orders in five assessment years were passed beyond that limitation period. Outcome: the impugned final assessment orders were quashed as time barred.
Interplay between limitation under section 144C(13) and section 153 was examined, with the tribunal considering the Madras High Court view that the two provisions are inter dependent and overlapping for matters under section 92CA; the tribunal concluded the timeline for passing final assessment orders must be determined with reference to section 144C read with section 153 and found the final assessment orders in five assessment years were passed beyond that limitation period. Outcome: the impugned final assessment orders were quashed as time barred.
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