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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...
Appellant challenged inclusion of royalty and cost of advertisement incurred in India in assessable value of imported goods u/rs 10(1)(c) and 10(1)(e) of Customs Valuation Rules 2007 involving related party transaction. SC concurred with CESTAT's view that appellant's obligation under agreement to be responsible for sales, distribution, and expenditure in consultation with seller does not attract Rule 10(1)(e). Appeal dismissed.
Appellant challenged inclusion of royalty and cost of advertisement incurred in India in assessable value of imported goods u/rs 10(1)(c) and 10(1)(e) of Customs Valuation Rules 2007 involving related party transaction. SC concurred with CESTAT's view that appellant's obligation under agreement to be responsible for sales, distribution, and expenditure in consultation with seller does not attract Rule 10(1)(e). Appeal dismissed.
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