Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
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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