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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...
Admittedly, excise duty is leviable on goods manufactured and if there is no manufacturing activity involved, as held by the lower authorities, for the purpose of denying the benefit of exemption notification, how the excise duty can be confirmed by applying the full rate of the same value of activity. Even as per the Revenue there is no manufacture and if that be so, no excise duty demand can stay. - AT
Admittedly, excise duty is leviable on goods manufactured and if there is no manufacturing activity involved, as held by the lower authorities, for the purpose of denying the benefit of exemption notification, how the excise duty can be confirmed by applying the full rate of the same value of activity. Even as per the Revenue there is no manufacture and if that be so, no excise duty demand can stay. - AT
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