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 110A of the Customs Act makes all seized goods eligible for provisional release, subject to the competent authority's discretionary assessment of entitlement. Goods notified under Section 123 cannot be categorically excluded from provisional release through CBIC Circular No. 35/2017-Cus. An executive circular cannot add exclusions absent from, or override, the parent statute. The Tribunal's direction for provisional release was therefore sustained, and the appeal challenging that direction was dismissed.
Section 110A of the Customs Act makes all seized goods eligible for provisional release, subject to the competent authority's discretionary assessment of entitlement. Goods notified under Section 123 cannot be categorically excluded from provisional release through CBIC Circular No. 35/2017-Cus. An executive circular cannot add exclusions absent from, or override, the parent statute. The Tribunal's direction for provisional release was therefore sustained, and the appeal challenging that direction was dismissed.
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