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...
Demand and penalty-initiation notices cannot rest on an order expressly issued as a draft assessment order. Where proposed disallowances remain proposals, no demand or penalty notice is issued, and the taxpayer retains the right to accept variations or object before final assessment, the payable sum has not been finally determined. Such a defect is not a mere uploading error curable through Section 292B, especially without a subsequent corrective or clarificatory order. Draft assessment procedure is also unavailable where the Transfer Pricing Officer makes no variation to returned income from international transactions; the taxpayer is then not an eligible assessee under Section 144C. The draft order and consequential notices were set aside.
Demand and penalty-initiation notices cannot rest on an order expressly issued as a draft assessment order. Where proposed disallowances remain proposals, no demand or penalty notice is issued, and the taxpayer retains the right to accept variations or object before final assessment, the payable sum has not been finally determined. Such a defect is not a mere uploading error curable through Section 292B, especially without a subsequent corrective or clarificatory order. Draft assessment procedure is also unavailable where the Transfer Pricing Officer makes no variation to returned income from international transactions; the taxpayer is then not an eligible assessee under Section 144C. The draft order and consequential notices were set aside.
Note: It is a system-generated summary and is for quick reference only.