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...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Attachment of proceeds of crime may extend beyond assets initially identified, including subsequently traced proceeds and property of equivalent value where directly derived property is unavailable. Property acquired before the scheduled offence may be attached where later premium payments or funding are traced to layered proceeds of crime. An inadvertent reference to an unrelated entity does not invalidate attachment where other material establishes the generation and use of tainted funds, and transferable movable property may warrant attachment. Discharge of another person in predicate-offence proceedings does not determine the role of a separate person or the source of attached property. Attachment may reach proceeds held by persons not accused in the predicate offence. The foreign insurance policy's attachment was upheld and the appeal dismissed.
Attachment of proceeds of crime may extend beyond assets initially identified, including subsequently traced proceeds and property of equivalent value where directly derived property is unavailable. Property acquired before the scheduled offence may be attached where later premium payments or funding are traced to layered proceeds of crime. An inadvertent reference to an unrelated entity does not invalidate attachment where other material establishes the generation and use of tainted funds, and transferable movable property may warrant attachment. Discharge of another person in predicate-offence proceedings does not determine the role of a separate person or the source of attached property. Attachment may reach proceeds held by persons not accused in the predicate offence. The foreign insurance policy's attachment was upheld and the appeal dismissed.
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