Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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AT upheld the Provisional Attachment Order under the PMLA against the appellant's properties, finding that the appellant failed to discharge the statutory burden of proving the legitimate source of funds used for their acquisition. The bank statements showed deposits with narrations "TRF" and "Cash" preceding part-payments of consideration, but the nature and source of these deposits remained unexplained. AT held that "reasons to believe" under S. 5(1) PMLA were properly recorded, as the Joint Director had elaborately set out the predicate (scheduled) offence, the alleged leaking of examination papers for consideration, and the related financial transactions. Finding no legal infirmity, AT dismissed the appeal and confirmed the attachment.
AT upheld the Provisional Attachment Order under the PMLA against the appellant's properties, finding that the appellant failed to discharge the statutory burden of proving the legitimate source of funds used for their acquisition. The bank statements showed deposits with narrations "TRF" and "Cash" preceding part-payments of consideration, but the nature and source of these deposits remained unexplained. AT held that "reasons to believe" under S. 5(1) PMLA were properly recorded, as the Joint Director had elaborately set out the predicate (scheduled) offence, the alleged leaking of examination papers for consideration, and the related financial transactions. Finding no legal infirmity, AT dismissed the appeal and confirmed the attachment.
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