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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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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Disallowance of making charges - If the making charges rate as determined by the Revenue at Rs.3/- per gram has to be considered, the aforesaid karigar’s net profit declared by them from the business in their respective tax returns would be higher than the gross receipts of making charges at Rs.3/- per gram. This itself goes to prove that the making charges cannot be at Rs.3/- per gram. - making charges paid by the assessee ranging from Rs.12/- to Rs.13/- per gram is acceptable - AT
Disallowance of making charges - If the making charges rate as determined by the Revenue at Rs.3/- per gram has to be considered, the aforesaid karigar’s net profit declared by them from the business in their respective tax returns would be higher than the gross receipts of making charges at Rs.3/- per gram. This itself goes to prove that the making charges cannot be at Rs.3/- per gram. - making charges paid by the assessee ranging from Rs.12/- to Rs.13/- per gram is acceptable - AT
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