Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
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Proceeds of crime under the PMLA include property derived or obtained, directly or indirectly, from criminal activity relating to a scheduled offence, including its value. Registration of FIRs and charge-sheets alone does not establish that every asset of an accused person or company has that character. Bank-account analysis and PMLA statements tracing project escrow funds towards a property can establish a prima facie nexus. Intermingling of project funds with other money requires examination of the complete money trail; independent income, financial-statement disclosure, or tax-department awareness does not by itself break the connection. Such tracing supports confirmation of attachment.
Proceeds of crime under the PMLA include property derived or obtained, directly or indirectly, from criminal activity relating to a scheduled offence, including its value. Registration of FIRs and charge-sheets alone does not establish that every asset of an accused person or company has that character. Bank-account analysis and PMLA statements tracing project escrow funds towards a property can establish a prima facie nexus. Intermingling of project funds with other money requires examination of the complete money trail; independent income, financial-statement disclosure, or tax-department awareness does not by itself break the connection. Such tracing supports confirmation of attachment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
