Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Attachment of Bank Account - Orders passed u/s 83(1) of the CGST Act - Period of limitation - The court acknowledges the statutory provision cited by the petitioner, confirming that orders under Section 83(1) of the CGST Act have a lifespan of one year and cease to operate thereafter. As the orders in question have expired, the court finds no basis for continuing the attachment. - While the respondents admit to issuing a fresh attachment order on 13.12.2023, the court does not delve into the validity of this specific order. Instead, it reserves the petitioner's right to challenge the fresh attachment order separately, leaving the question of its validity open for future adjudication.
Attachment of Bank Account - Orders passed u/s 83(1) of the CGST Act - Period of limitation - The court acknowledges the statutory provision cited by the petitioner, confirming that orders under Section 83(1) of the CGST Act have a lifespan of one year and cease to operate thereafter. As the orders in question have expired, the court finds no basis for continuing the attachment. - While the respondents admit to issuing a fresh attachment order on 13.12.2023, the court does not delve into the validity of this specific order. Instead, it reserves the petitioner's right to challenge the fresh attachment order separately, leaving the question of its validity open for future adjudication.
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