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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...
Customs valuation dispute over imported melamine considers whether declared transaction value was inflated to evade anti dumping duty. Tribunal emphasises the transaction value principle (GATT) and requires actual negotiated price evidence rather than reliance on a published price bulletin; consequence: confirmation of ADD based solely on market journal prices and untested electronic or recorded statements is unsustainable. Tribunal also notes electronic evidence and recorded statements require tendering with opportunity for cross examination before an adjudicating authority; absence of corroborative, cogent evidence undermines findings of deliberate overvaluation for ADD evasion.
Customs valuation dispute over imported melamine considers whether declared transaction value was inflated to evade anti dumping duty. Tribunal emphasises the transaction value principle (GATT) and requires actual negotiated price evidence rather than reliance on a published price bulletin; consequence: confirmation of ADD based solely on market journal prices and untested electronic or recorded statements is unsustainable. Tribunal also notes electronic evidence and recorded statements require tendering with opportunity for cross examination before an adjudicating authority; absence of corroborative, cogent evidence undermines findings of deliberate overvaluation for ADD evasion.
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