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...
Property of equivalent value may be seized or frozen where direct proceeds of crime are unavailable; prior acquisition alone does not exclude property from action under the proceeds-of-crime definition. Retention of seized documents, digital devices and cash, and freezing of bank and Demat accounts were sustained where a majority shareholder and authorised signatory was linked to the company involved in alleged investment fraud, failed to deny material particulars, and did not disclose the property's source. A connected person likewise failed to establish an independent source for held funds and shares. The appeals challenging retention and freezing were dismissed.
Property of equivalent value may be seized or frozen where direct proceeds of crime are unavailable; prior acquisition alone does not exclude property from action under the proceeds-of-crime definition. Retention of seized documents, digital devices and cash, and freezing of bank and Demat accounts were sustained where a majority shareholder and authorised signatory was linked to the company involved in alleged investment fraud, failed to deny material particulars, and did not disclose the property's source. A connected person likewise failed to establish an independent source for held funds and shares. The appeals challenging retention and freezing were dismissed.
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