SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Section 110(5) permits provisional attachment of bank accounts only upon strict compliance with substantive and procedural conditions, including the Commissioner's approval. Provisional attachment orders issued without that approval, consequential extensions, and debit-freeze directions unsupported by written reasons or approval are invalid. Written attachment orders made after approval, during proceedings against the concerned exporters, and recording the proper officer's reasons satisfy the statutory requirements and remain effective. Extension of a provisional attachment requires a pre-decisional hearing and recorded reasons; an extension made without notice, hearing, or reasons cannot be cured by a later hearing and must be set aside, subject to fresh action in accordance with law.
Section 110(5) permits provisional attachment of bank accounts only upon strict compliance with substantive and procedural conditions, including the Commissioner's approval. Provisional attachment orders issued without that approval, consequential extensions, and debit-freeze directions unsupported by written reasons or approval are invalid. Written attachment orders made after approval, during proceedings against the concerned exporters, and recording the proper officer's reasons satisfy the statutory requirements and remain effective. Extension of a provisional attachment requires a pre-decisional hearing and recorded reasons; an extension made without notice, hearing, or reasons cannot be cured by a later hearing and must be set aside, subject to fresh action in accordance with law.
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