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...
The Appellate Tribunal held that the definition of 'proceeds of crime' encompasses not only the property derived or obtained directly or indirectly from criminal activity, but also any other property of equivalent value when the original proceeds are unavailable. The Adjudicating Authority's narrow interpretation of the definition was incorrect. The Tribunal set aside the Adjudicating Authority's order and remanded the case for fresh consideration within the statutory period, with parties to remain present on 10.12.2024. The appeal was allowed.
The Appellate Tribunal held that the definition of 'proceeds of crime' encompasses not only the property derived or obtained directly or indirectly from criminal activity, but also any other property of equivalent value when the original proceeds are unavailable. The Adjudicating Authority's narrow interpretation of the definition was incorrect. The Tribunal set aside the Adjudicating Authority's order and remanded the case for fresh consideration within the statutory period, with parties to remain present on 10.12.2024. The appeal was allowed.
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