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...
HC partially lifted provisional attachment orders on bank accounts in tax liability dispute. Account in HDFC Bank Limited was completely unfrozen, while State Bank of India account received partial relief with debit restrictions lifted up to Rs. 70 Lacs. The freeze order remains effective for amounts exceeding Rs. 70 Lacs in the SBI account. Court balanced taxpayer's operational needs with revenue protection, allowing limited access to funds while maintaining security for potential tax recovery. The ruling demonstrates judicial discretion in modifying attachment orders based on proportionality and business necessity considerations.
HC partially lifted provisional attachment orders on bank accounts in tax liability dispute. Account in HDFC Bank Limited was completely unfrozen, while State Bank of India account received partial relief with debit restrictions lifted up to Rs. 70 Lacs. The freeze order remains effective for amounts exceeding Rs. 70 Lacs in the SBI account. Court balanced taxpayer's operational needs with revenue protection, allowing limited access to funds while maintaining security for potential tax recovery. The ruling demonstrates judicial discretion in modifying attachment orders based on proportionality and business necessity considerations.
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