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 the subject land u/s 281B - Rights of transferee or a partner’s interest - The assessee in the case on hand is Inviddual / Partner. The provisional attachment is of the property, which belongs to the writ-applicant (Partnership Firm). The plain language of the provision of Section-281B is plain and simple. It provides for the attachment of the property of the assessee only and of no one-else. The golden rule of interpretation of the statutes is that the statute has to be construed according to its plain, literal and grammatical meaning, unless it leads to absurdity. The subject land i.e. Block No.142 not being the property of the assessee as such, was not open to provisional attachment. - HC
Provisional attachment of the subject land u/s 281B - Rights of transferee or a partner’s interest - The assessee in the case on hand is Inviddual / Partner. The provisional attachment is of the property, which belongs to the writ-applicant (Partnership Firm). The plain language of the provision of Section-281B is plain and simple. It provides for the attachment of the property of the assessee only and of no one-else. The golden rule of interpretation of the statutes is that the statute has to be construed according to its plain, literal and grammatical meaning, unless it leads to absurdity. The subject land i.e. Block No.142 not being the property of the assessee as such, was not open to provisional attachment. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4807
Join Channel
TaxTMI 
