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...
Challenge to order allowing the Enforcement Directorate (ED) to retain/seize/freeze documents, digital records, bank accounts seized during search conducted on 07.04.2017. ED directed to defreeze Credit Accounts (CC & BC Account) allowing appellant firm to clear outstanding loan liability, with direction not to dispose of properties securing CC Accounts. Karnataka Bank restrained from releasing more credit into CC Account. Saving and current account to remain frozen till final disposal of criminal trials. Appellant entitled to copies of relied upon documents/seized material and right to apply for release of un-relied documents if not required for further investigation. Appeal dismissed.
Challenge to order allowing the Enforcement Directorate (ED) to retain/seize/freeze documents, digital records, bank accounts seized during search conducted on 07.04.2017. ED directed to defreeze Credit Accounts (CC & BC Account) allowing appellant firm to clear outstanding loan liability, with direction not to dispose of properties securing CC Accounts. Karnataka Bank restrained from releasing more credit into CC Account. Saving and current account to remain frozen till final disposal of criminal trials. Appellant entitled to copies of relied upon documents/seized material and right to apply for release of un-relied documents if not required for further investigation. Appeal dismissed.
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