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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Sale advances supported by a seized agreement, receipt and subsequent conveyance were treated as explained sale consideration rather than unexplained money under section 69A. The notes state that any suppressed consideration would instead be considered under capital gains in the relevant assessment year, and the section 69A additions were vacated. For section 153C, the relevant date for exclusion is stated to be the search initiation date, not later receipt of seized material; the deeming provision is confined to identifying abated assessment years, so the jurisdictional challenge failed. The mechanical-approval challenge under section 153D also failed for lack of cogent supporting material. The consolidated satisfaction-note issue remained open.
Sale advances supported by a seized agreement, receipt and subsequent conveyance were treated as explained sale consideration rather than unexplained money under section 69A. The notes state that any suppressed consideration would instead be considered under capital gains in the relevant assessment year, and the section 69A additions were vacated. For section 153C, the relevant date for exclusion is stated to be the search initiation date, not later receipt of seized material; the deeming provision is confined to identifying abated assessment years, so the jurisdictional challenge failed. The mechanical-approval challenge under section 153D also failed for lack of cogent supporting material. The consolidated satisfaction-note issue remained open.
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