Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Money Laundering - provisional attachment order - Despite claiming innocence and presenting evidence of legitimate business transactions, the appellant's receipt of payments through non-existing companies raised suspicions. The Appellate Tribunal, while acknowledging the appellant's denial of involvement in criminal activities, upheld the attachment order due to insufficient evidence supporting innocence. The appellant was advised to pursue legal remedies against the alleged fraudulent party. Overall, the Tribunal found no grounds to intervene in the attachment order.
Money Laundering - provisional attachment order - Despite claiming innocence and presenting evidence of legitimate business transactions, the appellant's receipt of payments through non-existing companies raised suspicions. The Appellate Tribunal, while acknowledging the appellant's denial of involvement in criminal activities, upheld the attachment order due to insufficient evidence supporting innocence. The appellant was advised to pursue legal remedies against the alleged fraudulent party. Overall, the Tribunal found no grounds to intervene in the attachment order.
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