Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Money Laundering - Proceeds of crime - attachment of moveable property of the appellant - The tribunal analyzed PMLA Section 5(1), determining that attachment requires proceeds of crime and a likelihood of concealment or transfer. It interpreted 'proceeds of crime' based on a Supreme Court case, concluding that the disputed amount frozen by the police qualified as such. Since there was no risk of transfer or concealment due to the frozen status, the tribunal deemed the attachment unjustified under PMLA. It interfered with the attachment order, directing that it remains invalid as long as the disputed amount is frozen by the police, with automatic reinstatement if released.
Money Laundering - Proceeds of crime - attachment of moveable property of the appellant - The tribunal analyzed PMLA Section 5(1), determining that attachment requires proceeds of crime and a likelihood of concealment or transfer. It interpreted 'proceeds of crime' based on a Supreme Court case, concluding that the disputed amount frozen by the police qualified as such. Since there was no risk of transfer or concealment due to the frozen status, the tribunal deemed the attachment unjustified under PMLA. It interfered with the attachment order, directing that it remains invalid as long as the disputed amount is frozen by the police, with automatic reinstatement if released.
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