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...
Section 28(9A) of the Customs Act suspends the adjudication limitation period while a specified circumstance prevents determination of duty liability, with the statutory period recommencing when that circumstance ceases. Transfer of a matter to the Call Book is an administrative consequence of such deferment and does not independently create the exclusion period. Where noticees seek deferment because a connected writ petition and interim protection affect the underlying duty liability, those circumstances are directly relevant to non-determination. Noticees' own request for deferment may substantially satisfy the communication requirement. The limitation period consequently runs from dismissal of the connected writ petition, and adjudication within the ensuing unextended one-year period is timely.
Section 28(9A) of the Customs Act suspends the adjudication limitation period while a specified circumstance prevents determination of duty liability, with the statutory period recommencing when that circumstance ceases. Transfer of a matter to the Call Book is an administrative consequence of such deferment and does not independently create the exclusion period. Where noticees seek deferment because a connected writ petition and interim protection affect the underlying duty liability, those circumstances are directly relevant to non-determination. Noticees' own request for deferment may substantially satisfy the communication requirement. The limitation period consequently runs from dismissal of the connected writ petition, and adjudication within the ensuing unextended one-year period is timely.
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TaxTMI 
TaxTMI 
of 4888 
