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...
Provisional attachment lapses by operation of law once the prescribed one-year period expires, so continued freezing of bank accounts cannot be sustained. On that basis, the attachment was treated as having automatically ceased, and the petitioner was allowed to operate the accounts. Separately, cash credit accounts are not liable to provisional attachment, making their freezing independently unsustainable. The bank-account freeze, including the cash credit facilities, was therefore held to have come to an end, while all other contentions were left open.
Provisional attachment lapses by operation of law once the prescribed one-year period expires, so continued freezing of bank accounts cannot be sustained. On that basis, the attachment was treated as having automatically ceased, and the petitioner was allowed to operate the accounts. Separately, cash credit accounts are not liable to provisional attachment, making their freezing independently unsustainable. The bank-account freeze, including the cash credit facilities, was therefore held to have come to an end, while all other contentions were left open.
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