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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...
Inclusion in the value of supply as per section 15 of the CGST Act, 2017 or not - The appellant is a recipient of services in the subject case. The impugned transactions are not in relation to the supply of goods or services or both undertaken or proposed to be undertaken by the appellant and therefore, it is outside the purview of mandate given to Advance Ruling Authority/AppeIIate Authority on Advance Ruling. - AAAR
Inclusion in the value of supply as per section 15 of the CGST Act, 2017 or not - The appellant is a recipient of services in the subject case. The impugned transactions are not in relation to the supply of goods or services or both undertaken or proposed to be undertaken by the appellant and therefore, it is outside the purview of mandate given to Advance Ruling Authority/AppeIIate Authority on Advance Ruling. - AAAR
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