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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...
Valuation - inclusion of freight charges - though the authorities below have given the finding that sales were on FOR destination basis but no evidence in this regard has been discussed - the cost of transportation in the given circumstances is the one which has expressly been excluded in terms of Rule 5 of Valuation Rules. - The freight charges are not includible in the assessable value of liquid CO2 those being separately charged in the invoices and the gas was sold at the time of clearance from the factory of the appellant - AT
Valuation - inclusion of freight charges - though the authorities below have given the finding that sales were on FOR destination basis but no evidence in this regard has been discussed - the cost of transportation in the given circumstances is the one which has expressly been excluded in terms of Rule 5 of Valuation Rules. - The freight charges are not includible in the assessable value of liquid CO2 those being separately charged in the invoices and the gas was sold at the time of clearance from the factory of the appellant - AT
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