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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Petitioner challenged the provisional attachment of his bank account u/s 83 of the CGST Act by invoking the jurisdiction of the High Court under Article 226 of the Constitution. However, the Court found contradictions in the petitioner's statements regarding his permanent address and business location. Combined with the respondents' assertions of the petitioner being non-genuine, the Court concluded that the petitioner was committing fraud on both the Revenue and the Court. Consequently, the Court refused to exercise its discretionary jurisdiction and dismissed the petition.
Petitioner challenged the provisional attachment of his bank account u/s 83 of the CGST Act by invoking the jurisdiction of the High Court under Article 226 of the Constitution. However, the Court found contradictions in the petitioner's statements regarding his permanent address and business location. Combined with the respondents' assertions of the petitioner being non-genuine, the Court concluded that the petitioner was committing fraud on both the Revenue and the Court. Consequently, the Court refused to exercise its discretionary jurisdiction and dismissed the petition.
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