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...
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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