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...
The AT upheld the provisional attachment order under the Prevention of Money-Laundering framework, dismissing the appeals. The tribunal found that the assets of the director and relatives were properly treated as "proceeds of crime" within the statutory definition, including application of the second limb permitting attachment of property acquired prior to the offence when equivalent proceeds are unavailable or have been siphoned off. The AT declined to disturb the impugned order after applying settled judicial principles and authoritative precedent, concluding the attachment was justified on the record of alleged irregular loans, overvaluation and misappropriation. The appeals consequently fail and are dismissed.
The AT upheld the provisional attachment order under the Prevention of Money-Laundering framework, dismissing the appeals. The tribunal found that the assets of the director and relatives were properly treated as "proceeds of crime" within the statutory definition, including application of the second limb permitting attachment of property acquired prior to the offence when equivalent proceeds are unavailable or have been siphoned off. The AT declined to disturb the impugned order after applying settled judicial principles and authoritative precedent, concluding the attachment was justified on the record of alleged irregular loans, overvaluation and misappropriation. The appeals consequently fail and are dismissed.
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