Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Provisional attachment of bank account u/s 110(5) of Customs Act, 1962 requires proper officer's opinion on necessity to protect revenue or prevent smuggling. Order must reflect reasons, be served on account holder, and approved by Commissioner. Initial attachment limited to six months, extendable by recorded reasons after hearing account holder. Order must specify duration, be addressed to bank and account holder. Release communication with DIN mandatory on expiry or if attachment no longer required. Diligent examination of case facts, live nexus to purpose, and expedited adjudication emphasized.
Provisional attachment of bank account u/s 110(5) of Customs Act, 1962 requires proper officer's opinion on necessity to protect revenue or prevent smuggling. Order must reflect reasons, be served on account holder, and approved by Commissioner. Initial attachment limited to six months, extendable by recorded reasons after hearing account holder. Order must specify duration, be addressed to bank and account holder. Release communication with DIN mandatory on expiry or if attachment no longer required. Diligent examination of case facts, live nexus to purpose, and expedited adjudication emphasized.
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