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...
An assessment or transfer pricing order passed in the name of a dissolved amalgamating company is void ab initio when the successor entity had already informed the tax authorities of the amalgamation and furnished the NCLT-approved scheme. Applying Maruti Suzuki India Ltd., the ITAT held that such an error is not a curable procedural defect under section 292B. The transfer pricing order, draft assessment order and final assessment order, all issued after dissolution in the name and PAN of the non-existent company, were therefore bad in law.
An assessment or transfer pricing order passed in the name of a dissolved amalgamating company is void ab initio when the successor entity had already informed the tax authorities of the amalgamation and furnished the NCLT-approved scheme. Applying Maruti Suzuki India Ltd., the ITAT held that such an error is not a curable procedural defect under section 292B. The transfer pricing order, draft assessment order and final assessment order, all issued after dissolution in the name and PAN of the non-existent company, were therefore bad in law.
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