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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Adverse findings require articulation of the evidential basis and engagement with material facts; where an order imposes penalty on an individual for alleged aiding and abetting but records only conclusory statements that the person received and transferred funds without discussing or identifying supporting evidence, the lack of reasons is fatal and justifies setting aside the penalty and remittal. The operative legal point is that tribunals and adjudicating authorities must record reasoned findings tying conclusions to specific evidence, failing which the affected order cannot be sustained.
Adverse findings require articulation of the evidential basis and engagement with material facts; where an order imposes penalty on an individual for alleged aiding and abetting but records only conclusory statements that the person received and transferred funds without discussing or identifying supporting evidence, the lack of reasons is fatal and justifies setting aside the penalty and remittal. The operative legal point is that tribunals and adjudicating authorities must record reasoned findings tying conclusions to specific evidence, failing which the affected order cannot be sustained.
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