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 held that the initial provisional attachment order ceased by efflux of time after one year and, in absence of statutory authority for renewal or re-issuance, executive authorities lack power to impose provisional attachment repeatedly; such repetition amounts to executive overreach. The impugned order dated 1 May 2025 effecting a fourth attachment of the petitioner's bank account is quashed and set aside. The authorities are directed to de-freeze the petitioner's bank account forthwith, and in any event within three days from the date of the order. The petition is disposed of.
HC held that the initial provisional attachment order ceased by efflux of time after one year and, in absence of statutory authority for renewal or re-issuance, executive authorities lack power to impose provisional attachment repeatedly; such repetition amounts to executive overreach. The impugned order dated 1 May 2025 effecting a fourth attachment of the petitioner's bank account is quashed and set aside. The authorities are directed to de-freeze the petitioner's bank account forthwith, and in any event within three days from the date of the order. The petition is disposed of.
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