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...
Remand by a tribunal to the Transfer Pricing Officer is legally distinct from a reference initiated by the Assessing Officer; therefore the time-limit for giving effect to a tribunal remand is governed by the statutory provision applicable to fresh orders on appellate remand (the provision corresponding to Section 153(3) and the related giving-effect provision) and not by the extension mechanism that applies only to AO references. Applying the jurisdictional nature of limitation, the court found the period to give effect had expired on 31-03-2024, quashed the communication rejecting refund and directed payment of the excess tax with interest and timelines for compliance.
Remand by a tribunal to the Transfer Pricing Officer is legally distinct from a reference initiated by the Assessing Officer; therefore the time-limit for giving effect to a tribunal remand is governed by the statutory provision applicable to fresh orders on appellate remand (the provision corresponding to Section 153(3) and the related giving-effect provision) and not by the extension mechanism that applies only to AO references. Applying the jurisdictional nature of limitation, the court found the period to give effect had expired on 31-03-2024, quashed the communication rejecting refund and directed payment of the excess tax with interest and timelines for compliance.
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