Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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Provisional attachment of bank accounts under GST can be relaxed where substitute security adequately protects revenue. The High Court accepted the petitioner's fixed deposit as sufficient security, permitted operation of the attached accounts, and quashed the attachment only to that extent. The investigation, scrutiny of invoices and other material, and any future show cause notice were left unaffected. The deposit was directed to remain available for adjustment against any liability finally determined, and to be returned with accrued interest if the final adjudication favoured the petitioner.
Provisional attachment of bank accounts under GST can be relaxed where substitute security adequately protects revenue. The High Court accepted the petitioner's fixed deposit as sufficient security, permitted operation of the attached accounts, and quashed the attachment only to that extent. The investigation, scrutiny of invoices and other material, and any future show cause notice were left unaffected. The deposit was directed to remain available for adjustment against any liability finally determined, and to be returned with accrued interest if the final adjudication favoured the petitioner.
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