Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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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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