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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...
Reopening of assessment u/s 147 - In the case on hand, upon disclosure made by the assessee with regard to the date for put to use of the assets, the Assessing Officer thought fit not to disallow the depreciation claimed by the assessee. Therefore, when primary materials having been disclosed bonafide, a mere technical mistake committed by the auditor, could not be said to be an “omission” or “failure” to disclose fully and truly all material facts for the assessment by the assessee. - HC
Reopening of assessment u/s 147 - In the case on hand, upon disclosure made by the assessee with regard to the date for put to use of the assets, the Assessing Officer thought fit not to disallow the depreciation claimed by the assessee. Therefore, when primary materials having been disclosed bonafide, a mere technical mistake committed by the auditor, could not be said to be an “omission” or “failure” to disclose fully and truly all material facts for the assessment by the assessee. - HC
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