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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Non-declaration of dutiable gold articles is examined through the Customs Declaration Form, contemporaneous documentary evidence and the absence of independent material supporting an alternative account. The text addresses the evidentiary effect of unavailable airport CCTV footage where it was automatically erased before preservation was sought. It also considers the reliability of a retracted statement recorded under the Customs Act, particularly where signed disclosures, a Panchnama and the lack of contemporaneous proof of coercion provide corroboration. Judicial review under Article 226 is described as limited to perversity, no evidence or manifest illegality, rather than reappreciation of plausible factual findings.
Non-declaration of dutiable gold articles is examined through the Customs Declaration Form, contemporaneous documentary evidence and the absence of independent material supporting an alternative account. The text addresses the evidentiary effect of unavailable airport CCTV footage where it was automatically erased before preservation was sought. It also considers the reliability of a retracted statement recorded under the Customs Act, particularly where signed disclosures, a Panchnama and the lack of contemporaneous proof of coercion provide corroboration. Judicial review under Article 226 is described as limited to perversity, no evidence or manifest illegality, rather than reappreciation of plausible factual findings.
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