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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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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
FERA proceedings initiated based on show cause notice alleging misdeclaration of export goods value were dropped by Enforcement Directorate against assessee. Income tax additions made relying on documents seized during search, relating to subsequent years, were untenable as foundation of proceedings under 1961 Act stood nullified. Appellate Tribunal rightly held that no additions could be made in returned income for the year to which documents did not pertain, after FERA proceedings were quashed. No factual or legal infirmity in impugned orders.
FERA proceedings initiated based on show cause notice alleging misdeclaration of export goods value were dropped by Enforcement Directorate against assessee. Income tax additions made relying on documents seized during search, relating to subsequent years, were untenable as foundation of proceedings under 1961 Act stood nullified. Appellate Tribunal rightly held that no additions could be made in returned income for the year to which documents did not pertain, after FERA proceedings were quashed. No factual or legal infirmity in impugned orders.
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