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...
Penalty under Rule 26 for dealing in goods liable to confiscation requires proof that the person acquired, possessed or dealt with excisable goods knowing or believing them to be liable to confiscation. Allegations of clandestine removal require affirmative evidence across the production and supply chain, including unaccounted procurement and production, transport and clearance, identified buyers' receipt, and unaccounted consideration; recovered diaries or notepads alone do not establish their contents as true. Statements recorded during investigation may be relied on where examination and cross-examination opportunities were provided but not used, without violating natural justice.
Penalty under Rule 26 for dealing in goods liable to confiscation requires proof that the person acquired, possessed or dealt with excisable goods knowing or believing them to be liable to confiscation. Allegations of clandestine removal require affirmative evidence across the production and supply chain, including unaccounted procurement and production, transport and clearance, identified buyers' receipt, and unaccounted consideration; recovered diaries or notepads alone do not establish their contents as true. Statements recorded during investigation may be relied on where examination and cross-examination opportunities were provided but not used, without violating natural justice.
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