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...
A High Court held that a Dispute Resolution Panel direction was binding and could not be ignored by the Assessing Officer. Because no departmental appeal had been filed on the earlier years' issue, the addition made under section 40(a)(i) was contrary to the DRP's clear mandate and could not be sustained. The Court therefore exercised writ jurisdiction to quash the demand, including interest, relatable to that addition, despite the availability of an alternate appellate remedy. The remaining transfer pricing adjustment was left open to challenge in the ordinary appeal, with protection against limitation if filed within the time granted.
A High Court held that a Dispute Resolution Panel direction was binding and could not be ignored by the Assessing Officer. Because no departmental appeal had been filed on the earlier years' issue, the addition made under section 40(a)(i) was contrary to the DRP's clear mandate and could not be sustained. The Court therefore exercised writ jurisdiction to quash the demand, including interest, relatable to that addition, despite the availability of an alternate appellate remedy. The remaining transfer pricing adjustment was left open to challenge in the ordinary appeal, with protection against limitation if filed within the time granted.
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