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 orders of attachment issued u/s 83 can be challenged by filing objection u/r 159(5). Petitioner did not file objection. Respondents issued fresh provisional attachment orders as notices u/s 74 could not be served on petitioner, who prima facie avoided service. Provisional attachment orders, though drastic, are permissible to protect revenue interest. Petitioner did not apply for release of property by filing objection u/r 159(5) even after fresh attachment orders. Inquiry u/s 74 is ongoing. At this stage, there appears material for provisional attachment orders. Petitioner did not approach respondents u/r 159(5) and did not explain non-approach. Petitioner not entitled to writ remedy. Petition dismissed.
Provisional orders of attachment issued u/s 83 can be challenged by filing objection u/r 159(5). Petitioner did not file objection. Respondents issued fresh provisional attachment orders as notices u/s 74 could not be served on petitioner, who prima facie avoided service. Provisional attachment orders, though drastic, are permissible to protect revenue interest. Petitioner did not apply for release of property by filing objection u/r 159(5) even after fresh attachment orders. Inquiry u/s 74 is ongoing. At this stage, there appears material for provisional attachment orders. Petitioner did not approach respondents u/r 159(5) and did not explain non-approach. Petitioner not entitled to writ remedy. Petition dismissed.
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