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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...
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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...
CENVAT credit on Capital Goods - balance 50% of credit availed during subsequent years before the machinery put to use - The phrase, “in possession and use of the manufacturer of final products" was clear and unambiguous - The phrase calls for one and only one interpretation and does not call for any external aid to cull the meaning of the said phrase - Demand confirmed - HC
CENVAT credit on Capital Goods - balance 50% of credit availed during subsequent years before the machinery put to use - The phrase, “in possession and use of the manufacturer of final products" was clear and unambiguous - The phrase calls for one and only one interpretation and does not call for any external aid to cull the meaning of the said phrase - Demand confirmed - HC
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