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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...
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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...
Power of CIT(A) to allow set off of the losses during the course of assessment proceedings by way of revised computation instead of revised return u/s 139(5) - Supreme court decision restrict power of the assessing authority to entertain a claim for deduction otherwise than by a revised return and did not impinge on the powers of the appellate authority - CIT(A) rightly allowed the claim
Power of CIT(A) to allow set off of the losses during the course of assessment proceedings by way of revised computation instead of revised return u/s 139(5) - Supreme court decision restrict power of the assessing authority to entertain a claim for deduction otherwise than by a revised return and did not impinge on the powers of the appellate authority - CIT(A) rightly allowed the claim
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