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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...
Addition u/s 68 - whether Tribunal is right in law in accepting the contentions of the Assessee without giving an opportunity to the AO by way of a remand - the explanations in the context of Section 68 of the Income Tax Act have to be considered in the light of human probabilities and the explanations cannot be unreasonably rejected. - no substantial question of law arises. - HC
Addition u/s 68 - whether Tribunal is right in law in accepting the contentions of the Assessee without giving an opportunity to the AO by way of a remand - the explanations in the context of Section 68 of the Income Tax Act have to be considered in the light of human probabilities and the explanations cannot be unreasonably rejected. - no substantial question of law arises. - HC
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