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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
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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...
Faceless assessment regime mandated u/s 151A - Jurisdictional Assessing Officer not permitted to issue notice u/s 148, as it would breach Section 151A provisions - No concurrent jurisdiction of JAO and FAO for Section 148 notice or assessment/reassessment order issuance - Specific jurisdiction assigned to either JAO or FAO in Scheme, excluding the other - Accepting Revenue's argument would render faceless proceedings redundant - Act contrary to law by Authority must be quashed as invalid, without requiring prejudice establishment - Assessees entitled to assessment as per prescribed law and procedure - Action against assessee without due process itself causes prejudice - Decided in favor of assessee.
Faceless assessment regime mandated u/s 151A - Jurisdictional Assessing Officer not permitted to issue notice u/s 148, as it would breach Section 151A provisions - No concurrent jurisdiction of JAO and FAO for Section 148 notice or assessment/reassessment order issuance - Specific jurisdiction assigned to either JAO or FAO in Scheme, excluding the other - Accepting Revenue's argument would render faceless proceedings redundant - Act contrary to law by Authority must be quashed as invalid, without requiring prejudice establishment - Assessees entitled to assessment as per prescribed law and procedure - Action against assessee without due process itself causes prejudice - Decided in favor of assessee.
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