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...
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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Willful Defaulters - The Calcutta High Court, in its judgement, set aside and quashed the decisions of both the First Committee and the Review Committee (RC) declaring the petitioners as willful defaulters. The Court found that the reliance on the Transaction Audit Report (TAR) was legally untenable, as the report itself was inconclusive and rejected in related legal proceedings. The procedural lapses by the RC in not providing a reasoned order further vitiated its decision.
Willful Defaulters - The Calcutta High Court, in its judgement, set aside and quashed the decisions of both the First Committee and the Review Committee (RC) declaring the petitioners as willful defaulters. The Court found that the reliance on the Transaction Audit Report (TAR) was legally untenable, as the report itself was inconclusive and rejected in related legal proceedings. The procedural lapses by the RC in not providing a reasoned order further vitiated its decision.
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