Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Gold jewellery forming stock-in-trade was seized and its release was sought in writ proceedings. Since stock-in-trade is not liable to seizure under the proviso to section 132(1)(iii) of the Income-tax Act, wrongful seizure could not justify continued retention or conditional release on furnishing a bank guarantee. On being prima facie satisfied that the petitioners had discharged the onus to prove the nature and source of the assets, the court held that release must be granted without insisting on any security, in terms of the first proviso to section 132B(1)(i) and the applicable Board instruction. - HC
Gold jewellery forming stock-in-trade was seized and its release was sought in writ proceedings. Since stock-in-trade is not liable to seizure under the proviso to section 132(1)(iii) of the Income-tax Act, wrongful seizure could not justify continued retention or conditional release on furnishing a bank guarantee. On being prima facie satisfied that the petitioners had discharged the onus to prove the nature and source of the assets, the court held that release must be granted without insisting on any security, in terms of the first proviso to section 132B(1)(i) and the applicable Board instruction. - HC
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