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...
HC held that denial of cross-examination did not vitiate the assessment where the proceedings under section 153C were founded on seized loose sheets recovered during search, not on the statement of the person whose cross-examination was sought. Applying Andaman Timber Industries, the Court found that the statement was only corroborative and was not used as the basis of the assessment or penalty. As the impugned orders rested on seized material and not on the disputed statement, no procedural irregularity or breach of natural justice was made out. The writ petitions were dismissed, with liberty to pursue the appellate remedy.
HC held that denial of cross-examination did not vitiate the assessment where the proceedings under section 153C were founded on seized loose sheets recovered during search, not on the statement of the person whose cross-examination was sought. Applying Andaman Timber Industries, the Court found that the statement was only corroborative and was not used as the basis of the assessment or penalty. As the impugned orders rested on seized material and not on the disputed statement, no procedural irregularity or breach of natural justice was made out. The writ petitions were dismissed, with liberty to pursue the appellate remedy.
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