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...
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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