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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...
Assessment u/s 144B - Disallowance of commission paid to the Foreign Company and Local Agents/Parties and expenses incurred by the petitioner on account of purchase of bullion - The High court noted the petitioner's failure to satisfactorily explain the disallowed commission payments and purchases. It was highlighted that the petitioner did not provide necessary documents, such as GST returns in Form GST 2A, to substantiate the transactions. - Writ Petition dismissed.
Assessment u/s 144B - Disallowance of commission paid to the Foreign Company and Local Agents/Parties and expenses incurred by the petitioner on account of purchase of bullion - The High court noted the petitioner's failure to satisfactorily explain the disallowed commission payments and purchases. It was highlighted that the petitioner did not provide necessary documents, such as GST returns in Form GST 2A, to substantiate the transactions. - Writ Petition dismissed.
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