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...
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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