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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...
Refund of the service tax paid on the input services that remained unutilized - It goes without saying that once the application for refund which stood rejected by the competent authority under the statute has been set-aside and quashed by the appellate Tribunal, the orders of rejection would no longer remain in existence and as a consequence of the orders passed by the appellate Tribunal, the application for refund automatically becomes active and is liable to be processed from that stage itself without there being a necessity for moving a fresh application as has been contended by the learned counsel for the Department. - HC
Refund of the service tax paid on the input services that remained unutilized - It goes without saying that once the application for refund which stood rejected by the competent authority under the statute has been set-aside and quashed by the appellate Tribunal, the orders of rejection would no longer remain in existence and as a consequence of the orders passed by the appellate Tribunal, the application for refund automatically becomes active and is liable to be processed from that stage itself without there being a necessity for moving a fresh application as has been contended by the learned counsel for the Department. - HC
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