Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
Attachment of properties as proceeds of crime may be sustained where funds from money-laundering activities are traceable to their acquisition and no complete legitimate source is established. Active participation in MLM operations, rather than mere receipt of brokerage commission, supported the finding that the funds were tainted. A bank loan did not establish a legitimate source where its repayment remained unexplained. Continued receipt of rent from property held in another person's name indicated beneficial enjoyment and supported treating the ostensible transferee as a name-lender. The provisional attachment of the properties was therefore confirmed.
Attachment of properties as proceeds of crime may be sustained where funds from money-laundering activities are traceable to their acquisition and no complete legitimate source is established. Active participation in MLM operations, rather than mere receipt of brokerage commission, supported the finding that the funds were tainted. A bank loan did not establish a legitimate source where its repayment remained unexplained. Continued receipt of rent from property held in another person's name indicated beneficial enjoyment and supported treating the ostensible transferee as a name-lender. The provisional attachment of the properties was therefore confirmed.
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