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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...
Levy late fee u/s 234E - intimation u/s 200A - late fee imposed prior to 01.06.2015 - Section 234E of the Act by itself creates a liability and the liability to pay the late fee is not dependent on Section 200A(1)(c) of the Act which only prescribes the recovery mechanism - Levy of late fee is not dependent on Section 200A(1)(c) - Challenge to the order imposing the levy of late fee prior to 01.06.2015 stands rejected. - HC
Levy late fee u/s 234E - intimation u/s 200A - late fee imposed prior to 01.06.2015 - Section 234E of the Act by itself creates a liability and the liability to pay the late fee is not dependent on Section 200A(1)(c) of the Act which only prescribes the recovery mechanism - Levy of late fee is not dependent on Section 200A(1)(c) - Challenge to the order imposing the levy of late fee prior to 01.06.2015 stands rejected. - HC
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