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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...
CESTAT allowed the appeal and quashed and set aside the impugned order revoking the customs broker licence and imposing forfeiture/penalty to the extent it was predicated on alleged non-existent exporters. The Tribunal found that verification reports were supplied for only four exporters and that the Revenue adduced no contrary evidence for three; for the fourth the verification affirmatively indicated prior existence and GST filings until August 2019, with subsequent departure from premises. Given the insufficiency of proof on the majority of alleged non-existent exporters, the punitive measures could not be sustained and the impugned order was annulled.
CESTAT allowed the appeal and quashed and set aside the impugned order revoking the customs broker licence and imposing forfeiture/penalty to the extent it was predicated on alleged non-existent exporters. The Tribunal found that verification reports were supplied for only four exporters and that the Revenue adduced no contrary evidence for three; for the fourth the verification affirmatively indicated prior existence and GST filings until August 2019, with subsequent departure from premises. Given the insufficiency of proof on the majority of alleged non-existent exporters, the punitive measures could not be sustained and the impugned order was annulled.
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