Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
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Under the PMLA, continued freezing or retention of property requires material linking the property to proceeds of crime and a statutory finding that it is involved in money laundering. General allegations of bribery, unconnected to identified transactions or quantified proceeds held by the property holder, do not meet that standard; continued freezing based solely on investigative necessity is unsustainable. Attachment, seizure and freezing may extend to property held by persons not named in the scheduled offence or money-laundering proceedings. Reasons to believe for search or freezing must be recorded, but post-recording communication is not mandatory where the show-cause notice incorporates the relevant reasons. Filing a prosecution complaint does not remove the Appellate Tribunal's jurisdiction over a freezing-confirmation order.
Under the PMLA, continued freezing or retention of property requires material linking the property to proceeds of crime and a statutory finding that it is involved in money laundering. General allegations of bribery, unconnected to identified transactions or quantified proceeds held by the property holder, do not meet that standard; continued freezing based solely on investigative necessity is unsustainable. Attachment, seizure and freezing may extend to property held by persons not named in the scheduled offence or money-laundering proceedings. Reasons to believe for search or freezing must be recorded, but post-recording communication is not mandatory where the show-cause notice incorporates the relevant reasons. Filing a prosecution complaint does not remove the Appellate Tribunal's jurisdiction over a freezing-confirmation order.
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