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...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
The Tribunal upheld provisional attachment of flats, parking spaces and agricultural land as equivalent-value property under PMLA, finding that the assets were purchased during the period of criminal activity after receipt of funds treated as proceeds of crime. The appellants' claim that the properties were acquired before the scheduled offence was rejected because the record showed otherwise and no legitimate source of acquisition was proved. It also held that the date of registration of the criminal case was not decisive, and declined to apply Seema Garg in light of later Supreme Court and High Court interpretation that proceeds of crime can cover property of equivalent value. The confirmation of attachment was sustained and both appeals were dismissed.
The Tribunal upheld provisional attachment of flats, parking spaces and agricultural land as equivalent-value property under PMLA, finding that the assets were purchased during the period of criminal activity after receipt of funds treated as proceeds of crime. The appellants' claim that the properties were acquired before the scheduled offence was rejected because the record showed otherwise and no legitimate source of acquisition was proved. It also held that the date of registration of the criminal case was not decisive, and declined to apply Seema Garg in light of later Supreme Court and High Court interpretation that proceeds of crime can cover property of equivalent value. The confirmation of attachment was sustained and both appeals were dismissed.
Note: It is a system-generated summary and is for quick reference only.