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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...
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...
Refund of Additional Duty of Customs (CVD) demanded from respondent after GST introduction on imported goods - refund of duty paid on re-import - time limitation. Commissioner (Appeals) granted refund. Respondent not liable to pay CVD after GST implementation from 01.07.2007, but paid due to system error and appellant's insistence. Section 26A limitation not applicable as provisions governing re-import duty payment per Notification No. 46/2017 dated 30.06.2017. Once respondent paid drawback with interest as per Notification, not liable for demanded duty. Appeal dismissed.
Refund of Additional Duty of Customs (CVD) demanded from respondent after GST introduction on imported goods - refund of duty paid on re-import - time limitation. Commissioner (Appeals) granted refund. Respondent not liable to pay CVD after GST implementation from 01.07.2007, but paid due to system error and appellant's insistence. Section 26A limitation not applicable as provisions governing re-import duty payment per Notification No. 46/2017 dated 30.06.2017. Once respondent paid drawback with interest as per Notification, not liable for demanded duty. Appeal dismissed.
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