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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...
Addition u/s 43CA - difference in the value of sale consideration of the of property as shown by the assessee and value adopted by the Sub-Registrar for stamp duty purposes - ITAT held that Section 43CA, which mandates consideration of stamp duty value for tax purposes, is applicable. However, given the agreement and most payments were made in 2008, and considering the provision of Section 43CA(3), the tribunal found that the addition made by the AO was not justifiable, since the provisions are not retrospective.
Addition u/s 43CA - difference in the value of sale consideration of the of property as shown by the assessee and value adopted by the Sub-Registrar for stamp duty purposes - ITAT held that Section 43CA, which mandates consideration of stamp duty value for tax purposes, is applicable. However, given the agreement and most payments were made in 2008, and considering the provision of Section 43CA(3), the tribunal found that the addition made by the AO was not justifiable, since the provisions are not retrospective.
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