Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The appellant failed to prove the legitimate source for acquisition of the subject property, and the Appellate Tribunal upheld the Provisional Attachment Order treating the amount as proceeds of crime derived from NRHM funds. The prosecution complaint was filed within the prescribed time limit. At this interim stage, the attachment of properties continues till the final disposal of the prosecution case. The appeal regarding seizure of Rs. 9.50 lakh, treated as proceeds of crime, was also dismissed as the appellant could not provide authentic evidence for the cash transactions.
The appellant failed to prove the legitimate source for acquisition of the subject property, and the Appellate Tribunal upheld the Provisional Attachment Order treating the amount as proceeds of crime derived from NRHM funds. The prosecution complaint was filed within the prescribed time limit. At this interim stage, the attachment of properties continues till the final disposal of the prosecution case. The appeal regarding seizure of Rs. 9.50 lakh, treated as proceeds of crime, was also dismissed as the appellant could not provide authentic evidence for the cash transactions.
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