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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...
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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...
Condonation of delay of 5318 days in filing the appeal - The reasons set out in the affidavit filed in support of the petition to condone the delay of 5318 days i.e., nearly 14 years are unconvincing and do not furnish any cause much less "sufficient cause" for condoning the delay in filing the appeal, instead reveal a callous attitude and a casual approach in availing the right of appeal. - HC
Condonation of delay of 5318 days in filing the appeal - The reasons set out in the affidavit filed in support of the petition to condone the delay of 5318 days i.e., nearly 14 years are unconvincing and do not furnish any cause much less "sufficient cause" for condoning the delay in filing the appeal, instead reveal a callous attitude and a casual approach in availing the right of appeal. - HC
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