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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Review jurisdiction is limited to discovery of new and material evidence, an error apparent on the face of the record, or analogous sufficient reasons; review applications failed as they reargued matters already decided. The Assessing Authority lacked demonstrated competence or procedural fairness to nullify a certificate under the Income Declaration Scheme, 2016, and the declaration - supported by a Registered Valuer and tax payment - was not successfully impugned. Allegations of benami transactions rested on a retracted statement; absent independent corroborative evidence (bank records or transactional proof) provisional attachment could not be sustained. All review petitions dismissed.
Review jurisdiction is limited to discovery of new and material evidence, an error apparent on the face of the record, or analogous sufficient reasons; review applications failed as they reargued matters already decided. The Assessing Authority lacked demonstrated competence or procedural fairness to nullify a certificate under the Income Declaration Scheme, 2016, and the declaration - supported by a Registered Valuer and tax payment - was not successfully impugned. Allegations of benami transactions rested on a retracted statement; absent independent corroborative evidence (bank records or transactional proof) provisional attachment could not be sustained. All review petitions dismissed.
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