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...
Writ petition partly allowed. Order of provisional attachment of petitioner's immovable properties purchased prior to 2014 u/s 5(1) of PML Act set aside as without jurisdiction. Properties acquired before commission of alleged offence cannot be attached as proceeds of crime under PML Act. Though statutory remedies exist against provisional attachment orders, writ petition maintainable if order wholly without jurisdiction. HC observed provisional attachment order cannot be challenged before any authority, but Adjudicating Authority can examine legality only from date of its order, not provisional order date. Hence, if provisional attachment without jurisdiction, writ remedy available.
Writ petition partly allowed. Order of provisional attachment of petitioner's immovable properties purchased prior to 2014 u/s 5(1) of PML Act set aside as without jurisdiction. Properties acquired before commission of alleged offence cannot be attached as proceeds of crime under PML Act. Though statutory remedies exist against provisional attachment orders, writ petition maintainable if order wholly without jurisdiction. HC observed provisional attachment order cannot be challenged before any authority, but Adjudicating Authority can examine legality only from date of its order, not provisional order date. Hence, if provisional attachment without jurisdiction, writ remedy available.
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