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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...
Reassessment u/s 147 - fictitious F&O loss by manipulative client code modification - return was originally processed u/s 143(1) and notice u/s 148 was issued within four years - in DIT (Inv.) report the assessee was listed as one of beneficiaries - AO itself conducted enquiries prior to issuance of notice u/s 148 by issuing notice u/s 133(6) to Broker - AO also applied independent mind before reopening u/s 147
Reassessment u/s 147 - fictitious F&O loss by manipulative client code modification - return was originally processed u/s 143(1) and notice u/s 148 was issued within four years - in DIT (Inv.) report the assessee was listed as one of beneficiaries - AO itself conducted enquiries prior to issuance of notice u/s 148 by issuing notice u/s 133(6) to Broker - AO also applied independent mind before reopening u/s 147
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