Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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The AT dismissed the appeal and upheld the impugned attachment order, holding that it is not the Tribunal's function to adjudicate civil title disputes and appellants cannot assert ownership before this forum while title remains sub judice in the competent civil court. The AT affirmed that attachment of equivalent property as "value" is a provisional, balancing measure to secure assets and preserve proceeds of crime for PMLA confiscation; mere prior acquisition does not preclude attachment. The Tribunal found no requirement of direct nexus where property is attached as value, rejected the contention of absent material for risk of concealment or frustration, and declined to interfere with the PAO.
The AT dismissed the appeal and upheld the impugned attachment order, holding that it is not the Tribunal's function to adjudicate civil title disputes and appellants cannot assert ownership before this forum while title remains sub judice in the competent civil court. The AT affirmed that attachment of equivalent property as "value" is a provisional, balancing measure to secure assets and preserve proceeds of crime for PMLA confiscation; mere prior acquisition does not preclude attachment. The Tribunal found no requirement of direct nexus where property is attached as value, rejected the contention of absent material for risk of concealment or frustration, and declined to interfere with the PAO.
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