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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...
Provisional attachment under the PMLA was sustained where investigators established a prima facie nexus between alleged proceeds of crime and conversion of demonetized currency into bullion and sale of jewellery, attracting the definition of proceeds of crime and prompting action under the Act; consequence: confirmation of attachment. The Tribunal affirmed that an undivided share in immovable property may be attached and physical divisibility or eviction is not required at the attachment stage; consequence: 50% attachment upheld. The claimant bears the burden to prove an attached portion is untainted and mere EMI payments or financial contribution without title do not establish ownership; consequence: impleadment and appeals dismissed.
Provisional attachment under the PMLA was sustained where investigators established a prima facie nexus between alleged proceeds of crime and conversion of demonetized currency into bullion and sale of jewellery, attracting the definition of proceeds of crime and prompting action under the Act; consequence: confirmation of attachment. The Tribunal affirmed that an undivided share in immovable property may be attached and physical divisibility or eviction is not required at the attachment stage; consequence: 50% attachment upheld. The claimant bears the burden to prove an attached portion is untainted and mere EMI payments or financial contribution without title do not establish ownership; consequence: impleadment and appeals dismissed.
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