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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...
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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...
Extended period of limitation - if Cenvat Credit has been allowed in respect of the same services to the other assessee’s there is no justifiable reason for denying the same to the present appellant - after the lapse of a considerable time after the audit, revenue proceeded to issue this show cause notice invoking suppression of facts. What is the reason for invoking suppression or other ingredients required for invoking an extended period in this case - no ground existed for invoking the extended period of limitation in the present case. - AT
Extended period of limitation - if Cenvat Credit has been allowed in respect of the same services to the other assessee’s there is no justifiable reason for denying the same to the present appellant - after the lapse of a considerable time after the audit, revenue proceeded to issue this show cause notice invoking suppression of facts. What is the reason for invoking suppression or other ingredients required for invoking an extended period in this case - no ground existed for invoking the extended period of limitation in the present case. - AT
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