SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
PMLA attachment may extend to Indian property of equivalent value where alleged proceeds of crime remain abroad, including property acquired before the alleged criminal activity or held in a spouse's name if funded by the accused and unsupported by an independent untainted source. Money-laundering is treated as a continuing offence, with timing assessed by reference to laundering acts and attachment; the value-of-proceeds limb independently supports equivalent-value attachment. A provisional attachment order may meet the reasons-to-believe requirement by recording the material, belief and risk of frustrating confiscation, without separate communication. Attachment proceedings do not determine the merits of a pending scheduled offence. Physical possession during pending prosecution is restricted to exceptional circumstances.
PMLA attachment may extend to Indian property of equivalent value where alleged proceeds of crime remain abroad, including property acquired before the alleged criminal activity or held in a spouse's name if funded by the accused and unsupported by an independent untainted source. Money-laundering is treated as a continuing offence, with timing assessed by reference to laundering acts and attachment; the value-of-proceeds limb independently supports equivalent-value attachment. A provisional attachment order may meet the reasons-to-believe requirement by recording the material, belief and risk of frustrating confiscation, without separate communication. Attachment proceedings do not determine the merits of a pending scheduled offence. Physical possession during pending prosecution is restricted to exceptional circumstances.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
