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 HC dismissed the appeal and refused to interfere with the Single Judge's order upholding the Provisional Attachment Order under the PMLA, affirming that writ jurisdiction under Article 226 must be exercised sparingly where an alternative efficacious remedy exists and only upon proof of mala fides, patent arbitrariness, or lack of jurisdiction. The Court held a PAO is a provisional safeguard for future PMLA proceedings and non-compliance with the first proviso to s.5(1) is not per se fatal to attachment proceedings. The Court found the designated authority had cogent material to believe proceeds of crime were invested and limited attachment to properties acquired during 2009-2014; quashing was denied.
The HC dismissed the appeal and refused to interfere with the Single Judge's order upholding the Provisional Attachment Order under the PMLA, affirming that writ jurisdiction under Article 226 must be exercised sparingly where an alternative efficacious remedy exists and only upon proof of mala fides, patent arbitrariness, or lack of jurisdiction. The Court held a PAO is a provisional safeguard for future PMLA proceedings and non-compliance with the first proviso to s.5(1) is not per se fatal to attachment proceedings. The Court found the designated authority had cogent material to believe proceeds of crime were invested and limited attachment to properties acquired during 2009-2014; quashing was denied.
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