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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...
Transfer of cases u/s 127 - assessee submitted that the AO had no jurisdiction to complete the assessment in Kolkata, since the jurisdiction over the assessee was duly transferred u/s 127 to chennai - Even a ‘right’ decision by a ‘wrong’ forum is no decision. It is non-existent in the eye of law. And hence a nullity. The assessment order under appeal is therefore no order in the eye of law, hence we quash the assessment order. - AT
Transfer of cases u/s 127 - assessee submitted that the AO had no jurisdiction to complete the assessment in Kolkata, since the jurisdiction over the assessee was duly transferred u/s 127 to chennai - Even a ‘right’ decision by a ‘wrong’ forum is no decision. It is non-existent in the eye of law. And hence a nullity. The assessment order under appeal is therefore no order in the eye of law, hence we quash the assessment order. - AT
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