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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...
HC upheld penalties under sections 114 and 114AA of Customs Act 1962 against appellants for fraudulent duty drawback claims through deliberate suppression and misdeclaration. Court found no infirmity in Tribunal's order requiring pre-deposit for appeal. Despite appellants' argument regarding change in law, HC emphasized that 2019 taxation regime applies without retrospective effect. Court noted appellants benefited from 8-year appeal pendency without pre-deposit payment. Appeals dismissed with directive to deposit specified amount within six weeks to pursue appeals, failing which Department authorized to proceed legally. Penalties and joint liability sustained, pre-deposit requirement affirmed as reasonable.
HC upheld penalties under sections 114 and 114AA of Customs Act 1962 against appellants for fraudulent duty drawback claims through deliberate suppression and misdeclaration. Court found no infirmity in Tribunal's order requiring pre-deposit for appeal. Despite appellants' argument regarding change in law, HC emphasized that 2019 taxation regime applies without retrospective effect. Court noted appellants benefited from 8-year appeal pendency without pre-deposit payment. Appeals dismissed with directive to deposit specified amount within six weeks to pursue appeals, failing which Department authorized to proceed legally. Penalties and joint liability sustained, pre-deposit requirement affirmed as reasonable.
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