Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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The AT partially allowed the appeal, finding procedural defects in the provisional attachment order (PAO) for a specific property. The tribunal determined that the PAO was issued after amendments to PMLA incorporating Prevention of Corruption Act provisions, thus not retrospectively invalid. However, the order was set aside due to failure to issue show cause notice (SCN) to the co-owner as mandated under Section 8(1) of PMLA. Consequently, the PAO for the specific flat at Patel Nagar was quashed, with the attachment order being declared invalid for procedural non-compliance.
The AT partially allowed the appeal, finding procedural defects in the provisional attachment order (PAO) for a specific property. The tribunal determined that the PAO was issued after amendments to PMLA incorporating Prevention of Corruption Act provisions, thus not retrospectively invalid. However, the order was set aside due to failure to issue show cause notice (SCN) to the co-owner as mandated under Section 8(1) of PMLA. Consequently, the PAO for the specific flat at Patel Nagar was quashed, with the attachment order being declared invalid for procedural non-compliance.
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