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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...
Clandestine removal demand based on electricity consumption not sustainable as mere electricity consumption cannot be the sole basis for determining duty liability. Demand based on ledger pages recovered from Director's briefcase and accepted by him confirmed. Demand based on documents recovered from Directors' residences and accepted by Director confirmed. Demand for risers and runners based on electricity consumption set aside. Demand for shortage in raw material set aside due to lack of evidence. Demand for inadmissible Cenvat credit on scrap receipt from sister concern set aside as alleged transactions were paper transactions only. Equivalent penalties set aside or confirmed accordingly.
Clandestine removal demand based on electricity consumption not sustainable as mere electricity consumption cannot be the sole basis for determining duty liability. Demand based on ledger pages recovered from Director's briefcase and accepted by him confirmed. Demand based on documents recovered from Directors' residences and accepted by Director confirmed. Demand for risers and runners based on electricity consumption set aside. Demand for shortage in raw material set aside due to lack of evidence. Demand for inadmissible Cenvat credit on scrap receipt from sister concern set aside as alleged transactions were paper transactions only. Equivalent penalties set aside or confirmed accordingly.
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