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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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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
CESTAT upheld the Commissioner of Customs (Appeals)'s decision dismissing the Revenue's appeal as time-barred. The review order was passed 20 days beyond the 90-day limitation period prescribed under Section 129D(3) of the Customs Act, 1962. The Revenue failed to demonstrate that sufficient cause was shown to the Board to obtain the mandated extension of 30 days under the proviso to Section 129D(3), nor did it file any application for condonation of delay before the Commissioner (Appeals). The Tribunal ruled that non-compliance with statutory time limitations cannot be mechanically condoned without adherence to legal mandates, particularly when no justifiable reasons were presented.
CESTAT upheld the Commissioner of Customs (Appeals)'s decision dismissing the Revenue's appeal as time-barred. The review order was passed 20 days beyond the 90-day limitation period prescribed under Section 129D(3) of the Customs Act, 1962. The Revenue failed to demonstrate that sufficient cause was shown to the Board to obtain the mandated extension of 30 days under the proviso to Section 129D(3), nor did it file any application for condonation of delay before the Commissioner (Appeals). The Tribunal ruled that non-compliance with statutory time limitations cannot be mechanically condoned without adherence to legal mandates, particularly when no justifiable reasons were presented.
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