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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...
Valuation of imported goods - Related person - Merely because there were transfer of funds in India amongst three importers will not make them related persons in terms of Rule 2(2) of CVR,2007. The concept of related person under the Customs Act, 1962 is applicable only with regard to imported goods. The transfer of funds from one entity to another entity in India cannot have any bearing on the concept of related person with regard to the provisions of the Customs Act and Valuation Rules made there under - all the three importers cannot be treated as related persons. - AT
Valuation of imported goods - Related person - Merely because there were transfer of funds in India amongst three importers will not make them related persons in terms of Rule 2(2) of CVR,2007. The concept of related person under the Customs Act, 1962 is applicable only with regard to imported goods. The transfer of funds from one entity to another entity in India cannot have any bearing on the concept of related person with regard to the provisions of the Customs Act and Valuation Rules made there under - all the three importers cannot be treated as related persons. - AT
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