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 ruled that provisional attachment under Section 110(5) of Customs Act, 1962 cannot exceed one year. Section 110A is inapplicable when attachment period expires, precluding extension beyond statutory timeframe. The court determined that once the one-year period lapses, the provisional attachment automatically ceases, and parties cannot invoke Section 110A to maintain the attachment. Consequently, the court granted relief by raising the attachment of petitioners' bank accounts, effectively terminating the provisional seizure.
HC ruled that provisional attachment under Section 110(5) of Customs Act, 1962 cannot exceed one year. Section 110A is inapplicable when attachment period expires, precluding extension beyond statutory timeframe. The court determined that once the one-year period lapses, the provisional attachment automatically ceases, and parties cannot invoke Section 110A to maintain the attachment. Consequently, the court granted relief by raising the attachment of petitioners' bank accounts, effectively terminating the provisional seizure.
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