Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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.
Note: It is a system-generated summary and is for quick reference only.
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