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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...
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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...
Section 108 statements were held admissible as substantive evidence to connect an implicated person with customs contraventions, and consistent recorded statements, corroborated by collateral material including forensic analysis of a detained mobile phone and other witness statements, furnished adequate material to sustain confiscation and penalties. The court accepted that the petitioner's communications, non-cooperation with summons and implicated statements of a money exchanger established knowledge and participation in improper export; differing relief granted to a passenger (redemption and re-export) did not warrant parity-based relief under equality principles. The petition was dismissed and impugned orders upheld.
Section 108 statements were held admissible as substantive evidence to connect an implicated person with customs contraventions, and consistent recorded statements, corroborated by collateral material including forensic analysis of a detained mobile phone and other witness statements, furnished adequate material to sustain confiscation and penalties. The court accepted that the petitioner's communications, non-cooperation with summons and implicated statements of a money exchanger established knowledge and participation in improper export; differing relief granted to a passenger (redemption and re-export) did not warrant parity-based relief under equality principles. The petition was dismissed and impugned orders upheld.
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