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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...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
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...
Validity of assessment order - Since, the levy of tax under the Act on the sale of goods during the course of import was an error apparent on the face of the record, the Assessing Officer in purported exercise of powers under Section 69(1) of the Act has rightly rectified the same. It is trite law that from the tenor of the order, the source of power can be traced. Therefore, merely because the Assessing Officer has referred to Section 39(1) of the Act, the same would not invalidate the order passed by the Assessing Officer. - HC
Validity of assessment order - Since, the levy of tax under the Act on the sale of goods during the course of import was an error apparent on the face of the record, the Assessing Officer in purported exercise of powers under Section 69(1) of the Act has rightly rectified the same. It is trite law that from the tenor of the order, the source of power can be traced. Therefore, merely because the Assessing Officer has referred to Section 39(1) of the Act, the same would not invalidate the order passed by the Assessing Officer. - HC
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