Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Retention of seized cash and vehicles during pending PMLA proceedings was upheld where a prosecution complaint was already pending in the same ECIR, and Section 8(3)(a) was held not to require a fresh complaint for each later seizure. The Tribunal also held that retention is not limited to property of named accused persons, so the challenge based on one appellant not being named failed. It accepted continued retention to trace a larger suspected quantum of proceeds of crime, rejected the objection that a separate Section 20 order was necessary, and found prima facie reasons to believe on the material and an insufficient explanation of the asset source. The appeals were dismissed.
Retention of seized cash and vehicles during pending PMLA proceedings was upheld where a prosecution complaint was already pending in the same ECIR, and Section 8(3)(a) was held not to require a fresh complaint for each later seizure. The Tribunal also held that retention is not limited to property of named accused persons, so the challenge based on one appellant not being named failed. It accepted continued retention to trace a larger suspected quantum of proceeds of crime, rejected the objection that a separate Section 20 order was necessary, and found prima facie reasons to believe on the material and an insufficient explanation of the asset source. The appeals were dismissed.
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