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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 Appellate Tribunal addressed several key issues. Firstly, on Transfer Pricing (TP) adjustment, it found errors in the CIT(A)'s decision as rectification was only sought for professional fees, not ESOP, leading to a flawed dismissal. The Tribunal directed a fresh review by the CIT(A) with proper consideration and opportunity for the assessee. Secondly, on comparable selection, the CIT(A) erred by only addressing the validity of comparables, neglecting other raised issues. The Tribunal ordered a reevaluation by the CIT(A) on all grounds. Lastly, on disallowance u/s 14A, the Tribunal remitted the matter back to CIT(A) for a thorough review of dividend income and related expenditures, emphasizing due process. Additionally, on disallowance u/s 14A for MAT purposes, the Tribunal found the CIT(A)'s order lacking and mandated a new review with proper consideration and hearing for the assessee.
The Appellate Tribunal addressed several key issues. Firstly, on Transfer Pricing (TP) adjustment, it found errors in the CIT(A)'s decision as rectification was only sought for professional fees, not ESOP, leading to a flawed dismissal. The Tribunal directed a fresh review by the CIT(A) with proper consideration and opportunity for the assessee. Secondly, on comparable selection, the CIT(A) erred by only addressing the validity of comparables, neglecting other raised issues. The Tribunal ordered a reevaluation by the CIT(A) on all grounds. Lastly, on disallowance u/s 14A, the Tribunal remitted the matter back to CIT(A) for a thorough review of dividend income and related expenditures, emphasizing due process. Additionally, on disallowance u/s 14A for MAT purposes, the Tribunal found the CIT(A)'s order lacking and mandated a new review with proper consideration and hearing for the assessee.
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