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...
PMLA adjudication permits a single-member Adjudicating Authority constituted by its Chairperson to include a non-judicial member, because attachment scrutiny does not transfer High Court functions and appellate review remains available. Provisional attachment requires recorded reasons to believe that non-attachment may frustrate proceedings; factual challenges to that satisfaction lie through the statutory appellate process. The Adjudicating Authority must independently record reasons to believe that a person possesses proceeds of crime before issuing notice. Properties acquired before the scheduled offence may also be attached in proceeds-of-crime proceedings. Challenges to the single-member order, attachment reasons, independent satisfaction and pre-offence property attachment were rejected in writ jurisdiction.
PMLA adjudication permits a single-member Adjudicating Authority constituted by its Chairperson to include a non-judicial member, because attachment scrutiny does not transfer High Court functions and appellate review remains available. Provisional attachment requires recorded reasons to believe that non-attachment may frustrate proceedings; factual challenges to that satisfaction lie through the statutory appellate process. The Adjudicating Authority must independently record reasons to believe that a person possesses proceeds of crime before issuing notice. Properties acquired before the scheduled offence may also be attached in proceeds-of-crime proceedings. Challenges to the single-member order, attachment reasons, independent satisfaction and pre-offence property attachment were rejected in writ jurisdiction.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
