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...
Failure to afford a personal hearing and reliance on portal-only notice rendered confirmation of show-cause proposals procedurally invalid; the assessment order was set aside and matter remanded. The article explains that while uploading notices on the IT portal can constitute service, the assessing officer must apply mind where the taxpayer does not respond and must explore other prescribed modes of service (for example, registered post with acknowledgement) to secure effective communication. Remedial directions require conditional payment, portal access to file replies, issuance of a clear 14-day notice by registered post fixing a personal hearing date, and fresh adjudication after hearing.
Failure to afford a personal hearing and reliance on portal-only notice rendered confirmation of show-cause proposals procedurally invalid; the assessment order was set aside and matter remanded. The article explains that while uploading notices on the IT portal can constitute service, the assessing officer must apply mind where the taxpayer does not respond and must explore other prescribed modes of service (for example, registered post with acknowledgement) to secure effective communication. Remedial directions require conditional payment, portal access to file replies, issuance of a clear 14-day notice by registered post fixing a personal hearing date, and fresh adjudication after hearing.
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