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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...
Validity of reassessment proceedings - non-service of notice u/s 148A(b) through e-mail - Denial of principle of natural justice - The High Court examined the evidence and found that the notice was effectively served at the petitioner's registered address, meeting the requirements of natural justice. As there was no rebuttal to the respondent's evidence, the Court upheld the validity of the notice and dismissed the petitioner's challenge. The Court also noted that the petitioner had alternative remedies available to address the assessment order.
Validity of reassessment proceedings - non-service of notice u/s 148A(b) through e-mail - Denial of principle of natural justice - The High Court examined the evidence and found that the notice was effectively served at the petitioner's registered address, meeting the requirements of natural justice. As there was no rebuttal to the respondent's evidence, the Court upheld the validity of the notice and dismissed the petitioner's challenge. The Court also noted that the petitioner had alternative remedies available to address the assessment order.
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