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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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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...
Addition u/s 69A r.w.s. 115BBE - unexplained jewellery fround in search proceddings - It is a fact on record that the income earned has been undisclosed and has been unearthed only due to the action u/s 132 and the jewellery is only application of such undisclosed income. - Hence, the provisions of Section 115BBE(1)(a) are equally applicable - AT
Addition u/s 69A r.w.s. 115BBE - unexplained jewellery fround in search proceddings - It is a fact on record that the income earned has been undisclosed and has been unearthed only due to the action u/s 132 and the jewellery is only application of such undisclosed income. - Hence, the provisions of Section 115BBE(1)(a) are equally applicable - AT
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