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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...
Reopening of assessment u/s 147 - reason to believe - No income appears to have escaped assessment as is visible from the explanation offered by assessee and consideration thereof by the authority in the present case on hand. Hence, an attempt has now been made to wriggle out from settled proposition of law by projecting that mistake might have been committed by the authority in not consciously considering the explanation. The said stand is not possible to be accepted by us - HC
Reopening of assessment u/s 147 - reason to believe - No income appears to have escaped assessment as is visible from the explanation offered by assessee and consideration thereof by the authority in the present case on hand. Hence, an attempt has now been made to wriggle out from settled proposition of law by projecting that mistake might have been committed by the authority in not consciously considering the explanation. The said stand is not possible to be accepted by us - HC
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