Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
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...
Method of valuation - Applicability of most appropriate rule for valuation - it is not the method of valuation that determines the applicability but that the method flows from the identification of the rule most apt for each transaction - ‘Job work’ existed before April 2007 and incorporation effected thereafter was not intended to cover every ‘job-worker’ as per common parlance but of specific situations contemplated in rule 10A of Central Excise Valuation (Determination of Price of Excisable Goods) Rules, 2000. That has not been demonstrated in the orders of the lower authorities. - AT
Method of valuation - Applicability of most appropriate rule for valuation - it is not the method of valuation that determines the applicability but that the method flows from the identification of the rule most apt for each transaction - ‘Job work’ existed before April 2007 and incorporation effected thereafter was not intended to cover every ‘job-worker’ as per common parlance but of specific situations contemplated in rule 10A of Central Excise Valuation (Determination of Price of Excisable Goods) Rules, 2000. That has not been demonstrated in the orders of the lower authorities. - AT
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