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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...
Disallowance of deduction u/s 10B - The tribunal examined the appellant's claim regarding deductions under Section 10B for miscellaneous incomes like scrap sales and tool development income. It referred to judicial precedents and the Act's provisions, concluding that such incomes, being integral to the business operations of Export Oriented Units (EOUs), qualify for deduction under Section 10B. This interpretation aligns with the legislative intent to encourage exports by offering tax incentives for incomes directly related to the business activity of EOUs.
Disallowance of deduction u/s 10B - The tribunal examined the appellant's claim regarding deductions under Section 10B for miscellaneous incomes like scrap sales and tool development income. It referred to judicial precedents and the Act's provisions, concluding that such incomes, being integral to the business operations of Export Oriented Units (EOUs), qualify for deduction under Section 10B. This interpretation aligns with the legislative intent to encourage exports by offering tax incentives for incomes directly related to the business activity of EOUs.
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