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 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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