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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...
Framing assessment u/s 143(3) without serving notices at the registered e-mail address - changing of the e-mail id - The ITAT found that the appellant had not communicated their change in email address to the revenue authorities, hence dismissing the appellant's claim of non-service of notices. - Concerning the disallowance of exceptional items, the tribunal determined that the shares issued by RFCL to the appellant constituted income, earned in exchange for the right to use the appellant's capital asset. Therefore, the disallowance made by the Assessing Officer was upheld. The tribunal directed the deletion of any income already offered for taxation in subsequent years to avoid double taxation.
Framing assessment u/s 143(3) without serving notices at the registered e-mail address - changing of the e-mail id - The ITAT found that the appellant had not communicated their change in email address to the revenue authorities, hence dismissing the appellant's claim of non-service of notices. - Concerning the disallowance of exceptional items, the tribunal determined that the shares issued by RFCL to the appellant constituted income, earned in exchange for the right to use the appellant's capital asset. Therefore, the disallowance made by the Assessing Officer was upheld. The tribunal directed the deletion of any income already offered for taxation in subsequent years to avoid double taxation.
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