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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...
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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...
Disallowance of tour and travel expenses - no details were forthcoming from the assessee to substantiate these travel and conveyance expenses and justify that these expenses were incurred wholly and exclusively for the purposes of business - Merely Rs. 10 lac of expenses were disallowed by the AO out of total travel and conveyance expenses of Rs. 1.90 crores incurred by the assessee during the year under consideration, as against total travelling and conveyance expenses of Rs. 1.20 crores incurred in the immediately preceding year - Additions confirmed - AT
Disallowance of tour and travel expenses - no details were forthcoming from the assessee to substantiate these travel and conveyance expenses and justify that these expenses were incurred wholly and exclusively for the purposes of business - Merely Rs. 10 lac of expenses were disallowed by the AO out of total travel and conveyance expenses of Rs. 1.90 crores incurred by the assessee during the year under consideration, as against total travelling and conveyance expenses of Rs. 1.20 crores incurred in the immediately preceding year - Additions confirmed - AT
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