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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HC held that seizure and continued retention of petitioner's 48 grams gold coins by Customs was unsustainable due to non-issuance of a statutory SCN under Section 124 read with Section 110(2) of the Customs Act. Rejecting the Department's contention of an "oral" SCN, HC followed binding precedent that, absent a proper notice within the prescribed period, seized goods must be returned. As no SCN was issued, no oral hearing afforded, and the goods remained with Customs, HC directed unconditional release of the seized gold coins to the petitioner, subject only to fulfilment of conditions stipulated by the Department.
HC held that seizure and continued retention of petitioner's 48 grams gold coins by Customs was unsustainable due to non-issuance of a statutory SCN under Section 124 read with Section 110(2) of the Customs Act. Rejecting the Department's contention of an "oral" SCN, HC followed binding precedent that, absent a proper notice within the prescribed period, seized goods must be returned. As no SCN was issued, no oral hearing afforded, and the goods remained with Customs, HC directed unconditional release of the seized gold coins to the petitioner, subject only to fulfilment of conditions stipulated by the Department.
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