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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...
Filing of Form Trans 1 in order to avail the unutilized credit - transitional credit - The order of the learned Single Judge was a straight, correct and innocuous order. Instead of complying with the same, the Department is seeking to raise all kinds of technical and hyper technical pleas before us in the present intra-court appeal. We strongly deprecate such practices of the Revenue Authorities in wasting the time of the court as well as wasting the resources of the State in filing such frivolous litigation. - HC
Filing of Form Trans 1 in order to avail the unutilized credit - transitional credit - The order of the learned Single Judge was a straight, correct and innocuous order. Instead of complying with the same, the Department is seeking to raise all kinds of technical and hyper technical pleas before us in the present intra-court appeal. We strongly deprecate such practices of the Revenue Authorities in wasting the time of the court as well as wasting the resources of the State in filing such frivolous litigation. - HC
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