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...
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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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