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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...
Violation of FERA provisions - foreign exchange seized at airport - reliance on statement recorded under Customs Act - validity of reliance despite retraction. Held: No retraction proved, mere retraction without justification cannot be accepted. Sufficient evidence to prove contravention - currency meant for delivery outside India without permission. Initiation of proceedings within sunset period of two years - issuance of show cause notice itself shows initiation within period. Acquittal in prosecution under Customs Act on technical ground of lack of sanction, not on merits, hence no bearing on present case. Appeal dismissed.
Violation of FERA provisions - foreign exchange seized at airport - reliance on statement recorded under Customs Act - validity of reliance despite retraction. Held: No retraction proved, mere retraction without justification cannot be accepted. Sufficient evidence to prove contravention - currency meant for delivery outside India without permission. Initiation of proceedings within sunset period of two years - issuance of show cause notice itself shows initiation within period. Acquittal in prosecution under Customs Act on technical ground of lack of sanction, not on merits, hence no bearing on present case. Appeal dismissed.
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