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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Explanation to Order 47 Rule 1 CPC restricts review jurisdiction where a judgment rests on a question of law later reversed or modified by a superior court; change in law or a subsequent coordinate or larger bench decision does not alone permit review. The tribunal's allowance of review and condonation of delay based solely on a liberty granted without determining the Explanation's bar was disapproved. Where a higher court has resolved conflicting bench decisions and directed which precedent governs, lower forums must follow that binding choice, and orders granting review contrary to that binding precedent were set aside.
Explanation to Order 47 Rule 1 CPC restricts review jurisdiction where a judgment rests on a question of law later reversed or modified by a superior court; change in law or a subsequent coordinate or larger bench decision does not alone permit review. The tribunal's allowance of review and condonation of delay based solely on a liberty granted without determining the Explanation's bar was disapproved. Where a higher court has resolved conflicting bench decisions and directed which precedent governs, lower forums must follow that binding choice, and orders granting review contrary to that binding precedent were set aside.
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