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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...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Conversion (Amendment) of shipping bills - substitution of ‘scheme code 19’ by ‘scheme code 03’ in the shipping bills and related invoices - benefits of a scheme - drawback - The CESTAt observed that the circular's restrictions exceeded statutory empowerment and lacked authority as it imposed rigid conditions not contemplated in the law. Emphasizing the distinction between 'documents' and 'bills of entry/shipping bills,' the Tribunal ruled that amendments could be denied only if they did not reflect facts at the time of clearance/export. - Considering the appellant's claim of eligibility for conversion under the Foreign Trade Policy, the Tribunal concluded that the rejection lacked comprehensive appreciation of amendment procedures and disregarded the spirit of guidance offered in the circular.
Conversion (Amendment) of shipping bills - substitution of ‘scheme code 19’ by ‘scheme code 03’ in the shipping bills and related invoices - benefits of a scheme - drawback - The CESTAt observed that the circular's restrictions exceeded statutory empowerment and lacked authority as it imposed rigid conditions not contemplated in the law. Emphasizing the distinction between 'documents' and 'bills of entry/shipping bills,' the Tribunal ruled that amendments could be denied only if they did not reflect facts at the time of clearance/export. - Considering the appellant's claim of eligibility for conversion under the Foreign Trade Policy, the Tribunal concluded that the rejection lacked comprehensive appreciation of amendment procedures and disregarded the spirit of guidance offered in the circular.
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