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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 dismissed the appeal, upholding the Commissioner's order extending time under the proviso to section 110(2) of the Customs Act, 1962. The Tribunal found no breach of natural justice: an SCN proposing the extension was served, the appellant's submissions were recorded and considered (paras 15-16), and reasons for extension were expressly stated. Material reasons included the appellant's non-cooperation, failure to respond to summons, and active delay of the investigation, together with the need to verify multiple factors including potential contraventions under the Foreign Trade (Development & Regulation) Act, 1992. The extension was held to be justified on the facts and in law; appeal dismissed.
CESTAT dismissed the appeal, upholding the Commissioner's order extending time under the proviso to section 110(2) of the Customs Act, 1962. The Tribunal found no breach of natural justice: an SCN proposing the extension was served, the appellant's submissions were recorded and considered (paras 15-16), and reasons for extension were expressly stated. Material reasons included the appellant's non-cooperation, failure to respond to summons, and active delay of the investigation, together with the need to verify multiple factors including potential contraventions under the Foreign Trade (Development & Regulation) Act, 1992. The extension was held to be justified on the facts and in law; appeal dismissed.
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