Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Provisional attachment of a bank account under Section 83 requires the competent authority to form a prior opinion before invoking the power. The cited Supreme Court authority treats the provision as draconian and insists on strict compliance with the statutory preconditions to prevent arbitrary interference with business activity. An attachment order that merely states it is issued to protect revenue, without recording the mandated opinion, is mechanically made and legally unsustainable; the bank account must be de-frozen.
Provisional attachment of a bank account under Section 83 requires the competent authority to form a prior opinion before invoking the power. The cited Supreme Court authority treats the provision as draconian and insists on strict compliance with the statutory preconditions to prevent arbitrary interference with business activity. An attachment order that merely states it is issued to protect revenue, without recording the mandated opinion, is mechanically made and legally unsustainable; the bank account must be de-frozen.
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