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...
A lapse of over eight years in giving effect to a Tribunal remand renders proceedings to exercise reassessment powers inordinate and barred by limitation. The note explains that Section 153 was amended in 2016 to prescribe time limits for giving effect to Tribunal orders but that even under the pre amendment regime an unexplained delay of this magnitude cannot be treated as reasonable. Applying the limitation principle and prior Division Bench authority construing the statutory scheme, the article concludes that an order made after such delay cannot be lawfully passed and refunds ordered earlier must stand.
A lapse of over eight years in giving effect to a Tribunal remand renders proceedings to exercise reassessment powers inordinate and barred by limitation. The note explains that Section 153 was amended in 2016 to prescribe time limits for giving effect to Tribunal orders but that even under the pre amendment regime an unexplained delay of this magnitude cannot be treated as reasonable. Applying the limitation principle and prior Division Bench authority construing the statutory scheme, the article concludes that an order made after such delay cannot be lawfully passed and refunds ordered earlier must stand.
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