Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Property provisionally attached may be treated as proceeds of crime where funds received from an entity allegedly involved in wrongful gains are not credibly explained as legitimate income or borrowing. The notes state that banking-channel transfers alone did not establish the claimed source of funds. A salary explanation lacked an appointment order, while the loan explanation lacked loan records or repayment evidence. On that basis, the receipt was not accepted as salary or loan and was characterised as proceeds of crime, resulting in confirmation of the provisional attachment and dismissal of the challenge.
Property provisionally attached may be treated as proceeds of crime where funds received from an entity allegedly involved in wrongful gains are not credibly explained as legitimate income or borrowing. The notes state that banking-channel transfers alone did not establish the claimed source of funds. A salary explanation lacked an appointment order, while the loan explanation lacked loan records or repayment evidence. On that basis, the receipt was not accepted as salary or loan and was characterised as proceeds of crime, resulting in confirmation of the provisional attachment and dismissal of the challenge.
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