Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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The AT dismissed both review applications. The review by the appellant was held meritless because the impugned findings constituted an appreciation of materials on record by a co-ordinate bench and did not disclose any error apparent on the face of the record; such factual findings are not reversible in review. The regulator's review was likewise dismissed as hyper-technical, the WTM and AO having adjudicated on the same factual matrix, and no prima facie error warranting review was demonstrated. The Tribunal noted that the AO's orders have been set aside and remitted for fresh disposal, but declined to entertain either review, ordering both applications dismissed.
The AT dismissed both review applications. The review by the appellant was held meritless because the impugned findings constituted an appreciation of materials on record by a co-ordinate bench and did not disclose any error apparent on the face of the record; such factual findings are not reversible in review. The regulator's review was likewise dismissed as hyper-technical, the WTM and AO having adjudicated on the same factual matrix, and no prima facie error warranting review was demonstrated. The Tribunal noted that the AO's orders have been set aside and remitted for fresh disposal, but declined to entertain either review, ordering both applications dismissed.
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