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...
Natural justice required a reasoned assessment of cryptocurrency exchanges' role, control over transactions and assets, ownership of crypto assets in pool wallets, knowledge of allegedly tainted transactions, and the nexus between frozen assets and proceeds of crime. The Tribunal found that the Adjudicating Authority had not addressed the platforms' material submissions or recorded specific findings on these issues. As the factual and legal questions required examination on the available evidence, the Tribunal set aside the order permitting retention of seized devices and continuation of freezing of bank funds and crypto assets, remanding the matters for fresh adjudication by a speaking order without deciding the merits conclusively.
Natural justice required a reasoned assessment of cryptocurrency exchanges' role, control over transactions and assets, ownership of crypto assets in pool wallets, knowledge of allegedly tainted transactions, and the nexus between frozen assets and proceeds of crime. The Tribunal found that the Adjudicating Authority had not addressed the platforms' material submissions or recorded specific findings on these issues. As the factual and legal questions required examination on the available evidence, the Tribunal set aside the order permitting retention of seized devices and continuation of freezing of bank funds and crypto assets, remanding the matters for fresh adjudication by a speaking order without deciding the merits conclusively.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
Join Channel
TaxTMI 
