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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...
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...
Addition u/s 68 - allowability of the expenditure under section 69C - ITAT concluding that genuineness of the high-seas sales cannot be doubted merely because the customs authorities have verified the documents at the time of clearing the goods for home consumption and while approving the high seas sale. - The genuineness of the transactions has been accepted on the basis of documentary evidence and other material gathered, which cannot be re-appreciated under Section 260A of the Act. - HC
Addition u/s 68 - allowability of the expenditure under section 69C - ITAT concluding that genuineness of the high-seas sales cannot be doubted merely because the customs authorities have verified the documents at the time of clearing the goods for home consumption and while approving the high seas sale. - The genuineness of the transactions has been accepted on the basis of documentary evidence and other material gathered, which cannot be re-appreciated under Section 260A of the Act. - HC
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