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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...
Money Laundering - proceeds of crime - conspiracy - provisional attachment of assets/properties of the petitioner - it is an admitted fact that there is no finding and it has not been identified that movable or immovable property linked directly with proceeds of crime but the same could not be done by the authority concerned. The material and reason has also not been disclosed so far as alienation of the property in question is concerned. There is no doubt that the authority is having the power to attach the property, but that power is required to be exercised in terms of the statute, which is lacking in the case in hand. - HC
Money Laundering - proceeds of crime - conspiracy - provisional attachment of assets/properties of the petitioner - it is an admitted fact that there is no finding and it has not been identified that movable or immovable property linked directly with proceeds of crime but the same could not be done by the authority concerned. The material and reason has also not been disclosed so far as alienation of the property in question is concerned. There is no doubt that the authority is having the power to attach the property, but that power is required to be exercised in terms of the statute, which is lacking in the case in hand. - HC
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