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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...
Import entitlement for dried cranberry was sustained because the product falls within the generic category 'fruit', and denial of duty-free import under post-export Duty Free Import Authorisations (DFIAs) lacked factual basis. The tribunal held transferable post-export DFIAs are not subject to an actual user condition for transferees, and struck down a value-cap public notice as invalid for lacking gazette notification. The assessing and firstappellate authorities failed to issue a speaking, reasoned order, warranting relief. The impugned orders were set aside and the licensing authority directed to restore/revalidate the lapsed DFIA for the unexpired period from bill of entry presentation.
Import entitlement for dried cranberry was sustained because the product falls within the generic category 'fruit', and denial of duty-free import under post-export Duty Free Import Authorisations (DFIAs) lacked factual basis. The tribunal held transferable post-export DFIAs are not subject to an actual user condition for transferees, and struck down a value-cap public notice as invalid for lacking gazette notification. The assessing and firstappellate authorities failed to issue a speaking, reasoned order, warranting relief. The impugned orders were set aside and the licensing authority directed to restore/revalidate the lapsed DFIA for the unexpired period from bill of entry presentation.
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