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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Levy of safeguard duty - Validity of show cause notice - bill of entry was finalized - department did not challenge the assessment by way of an appeal - Bill of Entry having been presented for clearance of goods though after the issuance of the Notification in question but before it was published so as to be effective and, therefore, the Notification imposing the safeguard duty shall not be applicable to the said Bill of Entry. - AT
Levy of safeguard duty - Validity of show cause notice - bill of entry was finalized - department did not challenge the assessment by way of an appeal - Bill of Entry having been presented for clearance of goods though after the issuance of the Notification in question but before it was published so as to be effective and, therefore, the Notification imposing the safeguard duty shall not be applicable to the said Bill of Entry. - AT
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