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...
Fresh adjudication of a service-tax demand was required after relevant work contracts and agreements were placed on record and the Department accepted reconsideration on the entire material. The claimed exemption had not been examined on its merits. The demand order and consequential penalties were set aside, with remand for reconsideration of the available and any further relevant documents after giving the petitioner an opportunity of hearing.
Fresh adjudication of a service-tax demand was required after relevant work contracts and agreements were placed on record and the Department accepted reconsideration on the entire material. The claimed exemption had not been examined on its merits. The demand order and consequential penalties were set aside, with remand for reconsideration of the available and any further relevant documents after giving the petitioner an opportunity of hearing.
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TaxTMI 
TaxTMI 
of 4888 
