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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...
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...
Extension of Customs Act jurisdiction to the Exclusive Economic Zone was applied to fish exports, requiring compliance with FEMA and its regulations; consignments transferred via an intermediary did not avoid this obligation, and contravention of the priorapproval requirement for deductions under Regulation 14C was held established. The appellants invoked lex non cogit ad impossibilia for regulatory impossibility; the tribunal noted the penalty provision lacks a mens rea requirement. Penalties were reduced in quantum as a matter of proportionality, with corporate and individual fines recalibrated and predeposits adjusted; appeals were partly allowed accordingly.
Extension of Customs Act jurisdiction to the Exclusive Economic Zone was applied to fish exports, requiring compliance with FEMA and its regulations; consignments transferred via an intermediary did not avoid this obligation, and contravention of the priorapproval requirement for deductions under Regulation 14C was held established. The appellants invoked lex non cogit ad impossibilia for regulatory impossibility; the tribunal noted the penalty provision lacks a mens rea requirement. Penalties were reduced in quantum as a matter of proportionality, with corporate and individual fines recalibrated and predeposits adjusted; appeals were partly allowed accordingly.
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