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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...
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...
Estimation of income on Cash Deposited in Bank Account - Kachha Arahtiya - Estimation of Net Profit (NP) @ 5% instead of 1% as claimed by the assessee - so far as kachha arahtias are concerned, the turnover does not include the sales affected on behalf of the principals and only the gross commission has to be considered for the purpose of section 44AB - it would be justified to apply a net profit rate of 1.5% as against 5% applied by the AO, on the Total Turn Over estimated - AT
Estimation of income on Cash Deposited in Bank Account - Kachha Arahtiya - Estimation of Net Profit (NP) @ 5% instead of 1% as claimed by the assessee - so far as kachha arahtias are concerned, the turnover does not include the sales affected on behalf of the principals and only the gross commission has to be considered for the purpose of section 44AB - it would be justified to apply a net profit rate of 1.5% as against 5% applied by the AO, on the Total Turn Over estimated - AT
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