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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...
The case involved the conversion of Ex-Bond Bill of Entry into Into-Bond Bill of Entry u/s 46(5) of the Customs Act. The appellant initially filed Bills of Entry for warehousing but later sought to convert them for home consumption without fulfilling necessary conditions. The Tribunal held that Section 46(5) can permit such conversion if there is no revenue loss or fraudulent intent. As no duty was paid and no clearance order issued, the appellant's request for conversion was considered valid. The appellant is liable to pay duty and interest as per Section 61(2) upon clearance. Any excess duty paid is refundable with interest. The appeal was disposed of in favor of the appellant.
The case involved the conversion of Ex-Bond Bill of Entry into Into-Bond Bill of Entry u/s 46(5) of the Customs Act. The appellant initially filed Bills of Entry for warehousing but later sought to convert them for home consumption without fulfilling necessary conditions. The Tribunal held that Section 46(5) can permit such conversion if there is no revenue loss or fraudulent intent. As no duty was paid and no clearance order issued, the appellant's request for conversion was considered valid. The appellant is liable to pay duty and interest as per Section 61(2) upon clearance. Any excess duty paid is refundable with interest. The appeal was disposed of in favor of the appellant.
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