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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...
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...
Disposal of the seized goods - Non-issuance of SCN - Conclusion of proceedings under Section 110(1D) of the Customs Act, without issuance of SCN - There are no merit in the contention that no notice is required to be served - In respect of seized gold, the proper officer is required to make an application before the Commissioner (Appeals) having jurisdiction instead of the Magistrate as required under Sub-section (1B) to Section 110 of the Customs Act. - Although the authority before whom an application is to be made was substituted, there was no amendment in the procedure to be followed. - HC
Disposal of the seized goods - Non-issuance of SCN - Conclusion of proceedings under Section 110(1D) of the Customs Act, without issuance of SCN - There are no merit in the contention that no notice is required to be served - In respect of seized gold, the proper officer is required to make an application before the Commissioner (Appeals) having jurisdiction instead of the Magistrate as required under Sub-section (1B) to Section 110 of the Customs Act. - Although the authority before whom an application is to be made was substituted, there was no amendment in the procedure to be followed. - HC
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