Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
A Tribunal upheld confirmation of provisional attachment under proceeds-of-crime law after finding a direct nexus between the properties and criminal activity. It held that the FIR was not exhaustive of the entire crime period and that investigation could validly establish a wider period from 2010 to 2020, rejecting the objection based on the narrower period initially stated in the FIR. The Tribunal also accepted statements showing that funds were provided by the mother for purchase of land and construction of flats, found no proof of an independent source, and treated unexplained cash deposits as further support for the attachment. The challenge to the source of acquisition therefore failed.
A Tribunal upheld confirmation of provisional attachment under proceeds-of-crime law after finding a direct nexus between the properties and criminal activity. It held that the FIR was not exhaustive of the entire crime period and that investigation could validly establish a wider period from 2010 to 2020, rejecting the objection based on the narrower period initially stated in the FIR. The Tribunal also accepted statements showing that funds were provided by the mother for purchase of land and construction of flats, found no proof of an independent source, and treated unexplained cash deposits as further support for the attachment. The challenge to the source of acquisition therefore failed.
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