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...
Invoking the extended five-year limitation under the Customs Act was held unsustainable where the Department had contemporaneous knowledge of the export and re import transactions; consequently, a show cause notice issued beyond the ordinary two year period was time barred. The legal principle applied prioritised the limitation regime over invoking extended limitation for collusion, willful misstatement or suppression absent fresh facts justifying extension. Because the demand, interest and penalties were founded solely on that extended limitation notice, the impugned order confirming duty, interest and penalty was set aside and the appeal allowed with consequential relief.
Invoking the extended five-year limitation under the Customs Act was held unsustainable where the Department had contemporaneous knowledge of the export and re import transactions; consequently, a show cause notice issued beyond the ordinary two year period was time barred. The legal principle applied prioritised the limitation regime over invoking extended limitation for collusion, willful misstatement or suppression absent fresh facts justifying extension. Because the demand, interest and penalties were founded solely on that extended limitation notice, the impugned order confirming duty, interest and penalty was set aside and the appeal allowed with consequential relief.
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