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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
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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...
Provisional release of goods - import of Dry Dates - non-furnishing of Phytosanitary Certificate of country of origin - The two parallel proceedings cannot continue together. As the show cause notice dated 30.06.2021 has been issued beyond the time limit prescribed under Section 110(2) of the Act, therefore, the show cause notice dt. 30.06.2021 is barred by limitation and the goods are required to be returned to the appellant. As the Show Cause Notice dated 16.11.2021 is not the subject matter of the appeal, therefore, the Revenue is at liberty to adjudicate the show cause notice dt. 16.11.2021 in accordance with law. - AT
Provisional release of goods - import of Dry Dates - non-furnishing of Phytosanitary Certificate of country of origin - The two parallel proceedings cannot continue together. As the show cause notice dated 30.06.2021 has been issued beyond the time limit prescribed under Section 110(2) of the Act, therefore, the show cause notice dt. 30.06.2021 is barred by limitation and the goods are required to be returned to the appellant. As the Show Cause Notice dated 16.11.2021 is not the subject matter of the appeal, therefore, the Revenue is at liberty to adjudicate the show cause notice dt. 16.11.2021 in accordance with law. - AT
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