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...
Omission of rule 96(10) of the CGST Rules without a saving clause applies to all proceedings pending on the date of omission, preventing the rule's restrictions from governing those matters. Section 6 of the General Clauses Act does not preserve pending proceedings after omission of a rule; their continuation requires an express saving provision or a statutory legal device. Unlike the Central Excise and Customs laws, GST law contains no comparable saving clause. CBIC may accept the Supreme Court's stated position.
Omission of rule 96(10) of the CGST Rules without a saving clause applies to all proceedings pending on the date of omission, preventing the rule's restrictions from governing those matters. Section 6 of the General Clauses Act does not preserve pending proceedings after omission of a rule; their continuation requires an express saving provision or a statutory legal device. Unlike the Central Excise and Customs laws, GST law contains no comparable saving clause. CBIC may accept the Supreme Court's stated position.
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