Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Where immovable property was transferred under a registered agreement to sell cum irrevocable power of attorney, with full consideration received and possession already handed over, the Tribunal treated the sale proceeds as linked to that land and not as a separate basis for retaining equivalent-value attachment of other assets. It held that the Enforcement Directorate could proceed against the land itself after due process and notice to the buyer, and that the attached movable property was to be released if the appellants furnished an undertaking disclaiming any claim over the land; otherwise, the attachment would continue. The separate provisional attachment of seized cash was unsustained because no independent justification was shown.
Where immovable property was transferred under a registered agreement to sell cum irrevocable power of attorney, with full consideration received and possession already handed over, the Tribunal treated the sale proceeds as linked to that land and not as a separate basis for retaining equivalent-value attachment of other assets. It held that the Enforcement Directorate could proceed against the land itself after due process and notice to the buyer, and that the attached movable property was to be released if the appellants furnished an undertaking disclaiming any claim over the land; otherwise, the attachment would continue. The separate provisional attachment of seized cash was unsustained because no independent justification was shown.
Note: It is a system-generated summary and is for quick reference only.