Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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