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 AT dismissed the appeal. The appellant company was found to be a sham entity established to launder proceeds of crime by an accused, Mr. Anurag Gupta. The ED complied with procedural requirements u/ss 5, 17 and 20 of PMLA for retaining seized properties prima facie involved in money laundering. The offence being independent, the appellant could be proceeded against despite not being named in the scheduled offence FIR/chargesheet, as it possessed unexplained proceeds of crime.
The AT dismissed the appeal. The appellant company was found to be a sham entity established to launder proceeds of crime by an accused, Mr. Anurag Gupta. The ED complied with procedural requirements u/ss 5, 17 and 20 of PMLA for retaining seized properties prima facie involved in money laundering. The offence being independent, the appellant could be proceeded against despite not being named in the scheduled offence FIR/chargesheet, as it possessed unexplained proceeds of crime.
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