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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...
Rejection of declaration for Tax Relief under the provisions of Sabka Vikas [Legacy Dispute Resolution) Scheme, 2019 - mistake apparent on record or sufficient reasons for review - It is undeniable that the attention of the Court is not drawn to material statutory provisions and the material circumstances. Thus, obvious sufficient reasons are established for review as envisaged under Order XLVII Rule 1 of CPC without calling for much probing. Therefore, this Court, answering the question for consideration in favour of the petitioner, opines that the order must be reviewed - Order recalled - HC
Rejection of declaration for Tax Relief under the provisions of Sabka Vikas [Legacy Dispute Resolution) Scheme, 2019 - mistake apparent on record or sufficient reasons for review - It is undeniable that the attention of the Court is not drawn to material statutory provisions and the material circumstances. Thus, obvious sufficient reasons are established for review as envisaged under Order XLVII Rule 1 of CPC without calling for much probing. Therefore, this Court, answering the question for consideration in favour of the petitioner, opines that the order must be reviewed - Order recalled - HC
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