Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Provisional attachment of Current Bank Accounts - Section 83 of GST - The authorities have acted in a blatantly highhanded and illegal manner - the action is clearly in violation of the petitioners’ rights for carrying on business under Article 19(1) of the Constitution of India and under Article 300A of the Constitution of India wherein the petitioners have been deprived of their property without authority of law - the actions of the Revenue in acting in contravention of Section 83(2) is condemnable, and accordingly costs are required to be imposed.
Provisional attachment of Current Bank Accounts - Section 83 of GST - The authorities have acted in a blatantly highhanded and illegal manner - the action is clearly in violation of the petitioners’ rights for carrying on business under Article 19(1) of the Constitution of India and under Article 300A of the Constitution of India wherein the petitioners have been deprived of their property without authority of law - the actions of the Revenue in acting in contravention of Section 83(2) is condemnable, and accordingly costs are required to be imposed.
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