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...
Liability for non-registration turned on allocation of operational roles under the MOU and Guidelines: uploading contracts to the foreign online portal was the foreign authority's distinct obligation, while the domestic authority's duty arose only to verify entries already reflected on that portal; consequently the domestic authority could not be held liable for the foreign authority's failure to upload. Challenges to fixation of the Country Cap and its allocation raised economic policy issues; the court declined to substitute judgment for a plausible policy decision absent manifest arbitrariness, unreasonableness, or mala fides, and found no violation of equality or trade rights.
Liability for non-registration turned on allocation of operational roles under the MOU and Guidelines: uploading contracts to the foreign online portal was the foreign authority's distinct obligation, while the domestic authority's duty arose only to verify entries already reflected on that portal; consequently the domestic authority could not be held liable for the foreign authority's failure to upload. Challenges to fixation of the Country Cap and its allocation raised economic policy issues; the court declined to substitute judgment for a plausible policy decision absent manifest arbitrariness, unreasonableness, or mala fides, and found no violation of equality or trade rights.
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