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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...
Levy of Service Tax - Composite Works Contracts prior to the introduction of the Finance Act, 2007, by which the Finance Act, 1994 came to be amended to introduce Section 65(105)(zzzza) pertaining to Works Contracts - The judgment in Larsen and Toubro Ltd. [2013 (9) TMI 853 - SUPREME COURT] has been correctly decided and does not call for a reconsideration insofar as the period prior to 1st June, 2007 is concerned - SC
Levy of Service Tax - Composite Works Contracts prior to the introduction of the Finance Act, 2007, by which the Finance Act, 1994 came to be amended to introduce Section 65(105)(zzzza) pertaining to Works Contracts - The judgment in Larsen and Toubro Ltd. [2013 (9) TMI 853 - SUPREME COURT] has been correctly decided and does not call for a reconsideration insofar as the period prior to 1st June, 2007 is concerned - SC
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