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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...
Confiscation of improperly imported consignment - import of natural rubber RSS3 - restriction on import - Private contracts are always subject to public policy and laws and if in terms of the changed law the performance under the contract becomes impossible, the contract becomes void. Further, in this case, although the contract was signed on 12.01.2016, subsequent actions in pursuance of the contract viz., issue of the commercial invoice on 25.01.2016 and dispatch of the goods by bill of lading dated 03.02.2016 took place well after the DGFT notification. Therefore, the appellant was clearly violated the law. - AT
Confiscation of improperly imported consignment - import of natural rubber RSS3 - restriction on import - Private contracts are always subject to public policy and laws and if in terms of the changed law the performance under the contract becomes impossible, the contract becomes void. Further, in this case, although the contract was signed on 12.01.2016, subsequent actions in pursuance of the contract viz., issue of the commercial invoice on 25.01.2016 and dispatch of the goods by bill of lading dated 03.02.2016 took place well after the DGFT notification. Therefore, the appellant was clearly violated the law. - AT
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