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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...
Reopening of assessment - notice u/s 148A(b) to wrong Email ID - notices are sent to (i) email ids that are no longer in use (ii) email ids of staff/accountants/chartered accountants who have created the profile of the assessee/file the income tax return and who are no longer in the employ/service of the assessee - The petitioner has not presented the facts in proper colour and has sought to take advantage of a technical mistake in the impugned order. This is wholly unappreciated and deprecated. - Petition dismissed with cost of Rs. One Lakh - HC
Reopening of assessment - notice u/s 148A(b) to wrong Email ID - notices are sent to (i) email ids that are no longer in use (ii) email ids of staff/accountants/chartered accountants who have created the profile of the assessee/file the income tax return and who are no longer in the employ/service of the assessee - The petitioner has not presented the facts in proper colour and has sought to take advantage of a technical mistake in the impugned order. This is wholly unappreciated and deprecated. - Petition dismissed with cost of Rs. One Lakh - HC
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