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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...
Introduction of block assessment provisions in cases of search u/s 132 and requisition u/s 132A for early finalization of search assessments, coordinated investigation, and reduction in multiplicity of proceedings. Block period consisting of previous years relevant to six assessment years preceding the previous year of search/requisition and period starting from 1st April of previous year of search/requisition till date of execution of last authorization. Regular assessments for block period to abate with one consolidated assessment. Assessment of total income including undisclosed income based on evidence found during search/requisition. Tax at 60% for block period without interest/penalty u/ss 234A/B/C and 270A. Penalty at 50% of tax payable on undisclosed income, nil if offered in return. Time limit of 12 months for block assessment, exclusion of 6 months from date of search to handing over of material. Evidence relating to international/specified domestic transactions after date of last authorization not considered for block period. Approval of higher authority required for notice/order. Section 144C not applicable.
Introduction of block assessment provisions in cases of search u/s 132 and requisition u/s 132A for early finalization of search assessments, coordinated investigation, and reduction in multiplicity of proceedings. Block period consisting of previous years relevant to six assessment years preceding the previous year of search/requisition and period starting from 1st April of previous year of search/requisition till date of execution of last authorization. Regular assessments for block period to abate with one consolidated assessment. Assessment of total income including undisclosed income based on evidence found during search/requisition. Tax at 60% for block period without interest/penalty u/ss 234A/B/C and 270A. Penalty at 50% of tax payable on undisclosed income, nil if offered in return. Time limit of 12 months for block assessment, exclusion of 6 months from date of search to handing over of material. Evidence relating to international/specified domestic transactions after date of last authorization not considered for block period. Approval of higher authority required for notice/order. Section 144C not applicable.
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