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...
The HC quashed two provisional attachment orders issued under s.83 CGST against the petitioner for lack of a reasoned opinion and absence of proceedings under s.74, holding the attachment notices arbitrary and without legal basis. The court directed immediate release of the attached bank accounts within 48 hours. As to the blocked electronic credit ledger, the HC ordered the revenue to consider the petitioner's reply, afford a personal hearing and pass a reasoned order in accordance with law within two weeks. The writ petition was disposed of on these terms.
The HC quashed two provisional attachment orders issued under s.83 CGST against the petitioner for lack of a reasoned opinion and absence of proceedings under s.74, holding the attachment notices arbitrary and without legal basis. The court directed immediate release of the attached bank accounts within 48 hours. As to the blocked electronic credit ledger, the HC ordered the revenue to consider the petitioner's reply, afford a personal hearing and pass a reasoned order in accordance with law within two weeks. The writ petition was disposed of on these terms.
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