Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Benami transaction - The petitioner argues that the transactions in question occurred before the amendment of the Act in 2016, making the notice and order invalid. They rely on Supreme Court judgments and decisions of appellate tribunals and other High Courts to support their position. - The High Court, however, finds that the show cause notice and provisional attachment order are provisional in nature and subject to judicial review by the adjudicating authority. It declines to entertain the petitions at this stage, emphasizing the availability of statutory alternative remedies.
Benami transaction - The petitioner argues that the transactions in question occurred before the amendment of the Act in 2016, making the notice and order invalid. They rely on Supreme Court judgments and decisions of appellate tribunals and other High Courts to support their position. - The High Court, however, finds that the show cause notice and provisional attachment order are provisional in nature and subject to judicial review by the adjudicating authority. It declines to entertain the petitions at this stage, emphasizing the availability of statutory alternative remedies.
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