Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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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