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...
Advance Authorisation IGST exemption remains subject to the pre-import condition; later fulfilment of export obligation or issuance of EODCs does not erase an established breach. Imports breaching that condition must instead be regularised under the prescribed procedure, with EODCs and redemption certificates relevant to liability. IGST breach must be quantified Bill of Entry-wise and raw material-wise by correlating imports, exports and chronology, while accounting for permitted clubbing of authorisations. The IGST demand requires fresh quantification on that basis. For the relevant period, recovery provisions did not independently authorise interest, confiscation, redemption fine or penalty for the IGST liability; those consequential liabilities were set aside, including interest on re-quantified IGST.
Advance Authorisation IGST exemption remains subject to the pre-import condition; later fulfilment of export obligation or issuance of EODCs does not erase an established breach. Imports breaching that condition must instead be regularised under the prescribed procedure, with EODCs and redemption certificates relevant to liability. IGST breach must be quantified Bill of Entry-wise and raw material-wise by correlating imports, exports and chronology, while accounting for permitted clubbing of authorisations. The IGST demand requires fresh quantification on that basis. For the relevant period, recovery provisions did not independently authorise interest, confiscation, redemption fine or penalty for the IGST liability; those consequential liabilities were set aside, including interest on re-quantified IGST.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
