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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Assessment u/s 153A - Validity of notice issued - the only pre-condition for issuance of the notice u/s 153A is the search itself. Thus unable to accept the argument of the petitioners to the effect that the transfer of the seized material is a pre-condition to the issuance of the notice u/s 153A as such a conclusion would tantamount to re-writing of the provision to read in such a condition, which is legally impermissible. - HC
Assessment u/s 153A - Validity of notice issued - the only pre-condition for issuance of the notice u/s 153A is the search itself. Thus unable to accept the argument of the petitioners to the effect that the transfer of the seized material is a pre-condition to the issuance of the notice u/s 153A as such a conclusion would tantamount to re-writing of the provision to read in such a condition, which is legally impermissible. - HC
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