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...
A High Court held that money-laundering under Section 3 of the PMLA is an independent offence, but prosecution still requires prima facie material showing proceeds of crime derived from a scheduled offence and the accused's involvement in a connected process or activity. Where the predicate investigation had already found that the petitioner was not a beneficiary and no independent material showed tainted funds, the PMLA case could not rest on assumption. The Court also held that a co-accused's Section 50 statement could not, by itself, found the prosecution, and that the warehouse-receipt transactions were not shown to be sham. Continuation of proceedings against the petitioner was quashed as abuse of process.
A High Court held that money-laundering under Section 3 of the PMLA is an independent offence, but prosecution still requires prima facie material showing proceeds of crime derived from a scheduled offence and the accused's involvement in a connected process or activity. Where the predicate investigation had already found that the petitioner was not a beneficiary and no independent material showed tainted funds, the PMLA case could not rest on assumption. The Court also held that a co-accused's Section 50 statement could not, by itself, found the prosecution, and that the warehouse-receipt transactions were not shown to be sham. Continuation of proceedings against the petitioner was quashed as abuse of process.
Note: It is a system-generated summary and is for quick reference only.