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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...
Vague show-cause notices proposing GST registration cancellation, and orders rejecting revocation, were held arbitrary because they did not deal with the petitioner's explanation for temporary discontinuance of business and showed no application of mind. The Court reiterated that a notice seeking cancellation must contain adequate reasons to enable an effective reply, and that a mechanical order passed without discussing the assessee's case violates natural justice. The impugned notices and consequential orders were quashed, registration was restored, and the department was left free to initiate fresh proceedings on a properly reasoned notice after granting a hearing.
Vague show-cause notices proposing GST registration cancellation, and orders rejecting revocation, were held arbitrary because they did not deal with the petitioner's explanation for temporary discontinuance of business and showed no application of mind. The Court reiterated that a notice seeking cancellation must contain adequate reasons to enable an effective reply, and that a mechanical order passed without discussing the assessee's case violates natural justice. The impugned notices and consequential orders were quashed, registration was restored, and the department was left free to initiate fresh proceedings on a properly reasoned notice after granting a hearing.
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