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 dominant issue was whether a single mortgage deed securing repayment under multiple loan agreements attracted stamp duty under Section 4 (one transaction) or Section 5 (several distinct matters) of the Stamp Act. The court held Section 4 requires commonality of a single transaction, whereas Section 5 applies where distinct transactions are embodied in one instrument, requiring aggregate duty as if separate instruments existed. As the four loan agreements imposed separate obligations and constituted independent transactions, execution of one consolidated mortgage deed could not convert them into a common transaction; duty was correctly assessed separately for each loan, along with deficit consequences. The challenge to the revisional order was rejected and the petition was dismissed. - HC
The dominant issue was whether a single mortgage deed securing repayment under multiple loan agreements attracted stamp duty under Section 4 (one transaction) or Section 5 (several distinct matters) of the Stamp Act. The court held Section 4 requires commonality of a single transaction, whereas Section 5 applies where distinct transactions are embodied in one instrument, requiring aggregate duty as if separate instruments existed. As the four loan agreements imposed separate obligations and constituted independent transactions, execution of one consolidated mortgage deed could not convert them into a common transaction; duty was correctly assessed separately for each loan, along with deficit consequences. The challenge to the revisional order was rejected and the petition was dismissed. - HC
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