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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...
Appellant produced wrong 'Country-of-Origin' certificate to claim notification benefit, amounting to mis-declaration and suppression of facts. Duty along with interest and reduced penalty u/s 114A paid. Claim for notification benefit at appellate stage rejected as certificates to be produced at clearance time. Levy of penalty u/s 114A and 114AA upheld, as both independent, but penalty under 114AA on proprietor set aside, as proprietor and firm being one entity, cannot be penalized twice for same offence. Impugned order modified, appeal partially allowed.
Appellant produced wrong 'Country-of-Origin' certificate to claim notification benefit, amounting to mis-declaration and suppression of facts. Duty along with interest and reduced penalty u/s 114A paid. Claim for notification benefit at appellate stage rejected as certificates to be produced at clearance time. Levy of penalty u/s 114A and 114AA upheld, as both independent, but penalty under 114AA on proprietor set aside, as proprietor and firm being one entity, cannot be penalized twice for same offence. Impugned order modified, appeal partially allowed.
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