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 property held by a person not accused of money laundering requires proof that proceeds of crime reached that person and funded acquisition of the property, or that the property constitutes equivalent-value property of a person involved in laundering. Alleged control of the purchasing company by an accused, based mainly on witness statements, does not replace evidence of a money trail. Bank-financed acquisition and the company's own savings were not shown to be proceeds of crime, layered proceeds, or assets belonging to the accused. The provisional attachment and its confirmation were therefore set aside.
Attachment of property held by a person not accused of money laundering requires proof that proceeds of crime reached that person and funded acquisition of the property, or that the property constitutes equivalent-value property of a person involved in laundering. Alleged control of the purchasing company by an accused, based mainly on witness statements, does not replace evidence of a money trail. Bank-financed acquisition and the company's own savings were not shown to be proceeds of crime, layered proceeds, or assets belonging to the accused. The provisional attachment and its confirmation were therefore set aside.
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