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...
The High Court considered a petition seeking revocation of a provisional attachment order u/s 281B of Fixed Deposit Receipts (FDRs). The ACIT (Hq) on behalf of PCIT (Central), Kanpur Nagar, approved the extension of the attachment. The assessee requested release of FDRs due to business hardship. The High Court order was referenced. The Ld. PCIT (Central) Kanpur revoked all provisional attachments u/s 281B. Immediate steps were directed for releasing the FDRs, with an action report due within a week. Corrective action was noted in response to the petition.
The High Court considered a petition seeking revocation of a provisional attachment order u/s 281B of Fixed Deposit Receipts (FDRs). The ACIT (Hq) on behalf of PCIT (Central), Kanpur Nagar, approved the extension of the attachment. The assessee requested release of FDRs due to business hardship. The High Court order was referenced. The Ld. PCIT (Central) Kanpur revoked all provisional attachments u/s 281B. Immediate steps were directed for releasing the FDRs, with an action report due within a week. Corrective action was noted in response to the petition.
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