Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
A partnership firm's crystallised tax dues may be recovered by issuing a garnishee notice against a partner's bank account when the recovery is directed under Section 79(1)(c)(i), not Section 83. The challenge failed because the impugned communication was on its face a recovery step after liability had crystallised, the demand against the firm itself had not been challenged, and partners are personally liable for the firm's dues. On those facts, no infirmity was found in the notice to the bank, and writ interference was unwarranted.
A partnership firm's crystallised tax dues may be recovered by issuing a garnishee notice against a partner's bank account when the recovery is directed under Section 79(1)(c)(i), not Section 83. The challenge failed because the impugned communication was on its face a recovery step after liability had crystallised, the demand against the firm itself had not been challenged, and partners are personally liable for the firm's dues. On those facts, no infirmity was found in the notice to the bank, and writ interference was unwarranted.
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