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...
Money-laundering liability requires prima facie material showing knowing participation, control, possession, projection or enjoyment of proceeds of crime. Mere facilitation, intermediary coordination or professional association does not establish culpability without evidence of intent and direct involvement. Uncorroborated statements of co-accused recorded under the PMLA, unsupported by independent documentary, electronic or other evidence, cannot alone sustain proceedings. Where no material shows execution of transactions, operation of accounts, participation in the predicate offence, benefit from alleged proceeds, or a prior meeting of minds, continuation of prosecution is oppressive and an abuse of process. Proceedings against the Chartered Accountant and intermediary were quashed.
Money-laundering liability requires prima facie material showing knowing participation, control, possession, projection or enjoyment of proceeds of crime. Mere facilitation, intermediary coordination or professional association does not establish culpability without evidence of intent and direct involvement. Uncorroborated statements of co-accused recorded under the PMLA, unsupported by independent documentary, electronic or other evidence, cannot alone sustain proceedings. Where no material shows execution of transactions, operation of accounts, participation in the predicate offence, benefit from alleged proceeds, or a prior meeting of minds, continuation of prosecution is oppressive and an abuse of process. Proceedings against the Chartered Accountant and intermediary were quashed.
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