Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Petitioners challenged the re-attachment of their third account by the Department after the initial attachment expired by operation of law u/s 83(2) of the Act. The Court held that once the attachment expires, the Department lacks jurisdiction to re-attach the same account. Consequently, the Court directed lifting of the attachment made on 30.08.2024 on petitioners' third account and ordered the account to be defreezed, as the re-attachment was without legal authority.
Petitioners challenged the re-attachment of their third account by the Department after the initial attachment expired by operation of law u/s 83(2) of the Act. The Court held that once the attachment expires, the Department lacks jurisdiction to re-attach the same account. Consequently, the Court directed lifting of the attachment made on 30.08.2024 on petitioners' third account and ordered the account to be defreezed, as the re-attachment was without legal authority.
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