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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...
Revision u/s 263 by CIT - - in the present appeals, the assessment orders have already been cancelled – meaning thereby it has extinguished, and therefore, no subsequent further proceedings can be initiated - Commissioner has committed an error by holding that “since the Revenue wants to keep the issue alive, it is necessary to pass such order”. Therefore, in view of the above discussions, the impugned orders are not sustainable in these assessment years. - AT
Revision u/s 263 by CIT - - in the present appeals, the assessment orders have already been cancelled – meaning thereby it has extinguished, and therefore, no subsequent further proceedings can be initiated - Commissioner has committed an error by holding that “since the Revenue wants to keep the issue alive, it is necessary to pass such order”. Therefore, in view of the above discussions, the impugned orders are not sustainable in these assessment years. - AT
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