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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...
CENVAT Credit - non-reversal of proportionate credit - From application of the definition of ‘exempted services’ in rule 2 (e) of CENVAT Credit Rules, 2004, to the facts leading to the impugned order, there are no doubt that the amendments in section 65 (105) of Finance Act, 1994 in relation to ‘endowment policies’ and ‘unit linked insurance plan (ULIP) policies’ cannot be held to have established ‘exempted services’ warranting any restriction on availment of CENVAT credit of ‘input services’ as provided for in the rule 6 of CENVAT Credit Rules, 2004. - AT
CENVAT Credit - non-reversal of proportionate credit - From application of the definition of ‘exempted services’ in rule 2 (e) of CENVAT Credit Rules, 2004, to the facts leading to the impugned order, there are no doubt that the amendments in section 65 (105) of Finance Act, 1994 in relation to ‘endowment policies’ and ‘unit linked insurance plan (ULIP) policies’ cannot be held to have established ‘exempted services’ warranting any restriction on availment of CENVAT credit of ‘input services’ as provided for in the rule 6 of CENVAT Credit Rules, 2004. - AT
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