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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Limited scrutiny cannot be expanded into complete scrutiny without the written approval mandated by CBDT Instruction No. 7/2014; the Tribunal found that the assessment was enlarged beyond the original capital gains issue without such approval, so the assessment was quashed. Section 69A was not barred merely because the share acquisition transactions related to time-barred years, as the Tribunal treated the deeming fiction as sufficient to permit enquiry. For section 54F, exemption cannot be denied solely because the residential property was not conveyed by a registered sale deed; where purchase and investment within the statutory period were shown, the denial was unsustainable. The appeal was allowed.
Limited scrutiny cannot be expanded into complete scrutiny without the written approval mandated by CBDT Instruction No. 7/2014; the Tribunal found that the assessment was enlarged beyond the original capital gains issue without such approval, so the assessment was quashed. Section 69A was not barred merely because the share acquisition transactions related to time-barred years, as the Tribunal treated the deeming fiction as sufficient to permit enquiry. For section 54F, exemption cannot be denied solely because the residential property was not conveyed by a registered sale deed; where purchase and investment within the statutory period were shown, the denial was unsustainable. The appeal was allowed.
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