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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...
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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...
Condonation of delay in filing appeal before the Commissioner (appeals) - There is no denial about the date of receipt of recovery proceedings and receipt of O-I-O by the appellant on 6th January, 2017. Commissioner (Appeals) is observed to have been silent about any cogent reason for not considering 6.01.2017 as the date of receipt. - the matter is remanded back to Commissioner (Appeals) directing him to rehear the matter after condoning the delay of 28 days and to adjudicate denovo on the merits of the case - AT
Condonation of delay in filing appeal before the Commissioner (appeals) - There is no denial about the date of receipt of recovery proceedings and receipt of O-I-O by the appellant on 6th January, 2017. Commissioner (Appeals) is observed to have been silent about any cogent reason for not considering 6.01.2017 as the date of receipt. - the matter is remanded back to Commissioner (Appeals) directing him to rehear the matter after condoning the delay of 28 days and to adjudicate denovo on the merits of the case - AT
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