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...
Properties treated as proceeds of crime remained attachable where the appellants failed to prove acquisition from independent lawful sources or payment of consideration. The Appellate Tribunal found that the respondent had established the foundational case that the assets originally stood with M/s AGFVIL and were later transferred through intermediary, namesake transactions without supporting proof of genuine purchase. For one appellant, the record showed only a shifted name without documentary evidence of consideration; for another, alleged loans, seller payment, and bank trail were not substantiated; for the third, the later explanation of source was inconsistent with her own statement and unsupported by material. The confirmation of the provisional attachment was upheld.
Properties treated as proceeds of crime remained attachable where the appellants failed to prove acquisition from independent lawful sources or payment of consideration. The Appellate Tribunal found that the respondent had established the foundational case that the assets originally stood with M/s AGFVIL and were later transferred through intermediary, namesake transactions without supporting proof of genuine purchase. For one appellant, the record showed only a shifted name without documentary evidence of consideration; for another, alleged loans, seller payment, and bank trail were not substantiated; for the third, the later explanation of source was inconsistent with her own statement and unsupported by material. The confirmation of the provisional attachment was upheld.
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