Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
The principal issue was whether provisional attachment of corporate properties was lawful as proceeds of crime were allegedly injected into the company via purchase of share warrants, subsequent conversion to equity, and loans routed through NBFCs controlled by the accused. The tribunal relied on detailed factual money-trail in the original complaint identifying extensive related entities and payments (including an additional payment of Rs. 39.75 crores) and found loans, even if repaid, originated from tainted funds; consequently the attachment was lawful and the appeals were dismissed. - AT
The principal issue was whether provisional attachment of corporate properties was lawful as proceeds of crime were allegedly injected into the company via purchase of share warrants, subsequent conversion to equity, and loans routed through NBFCs controlled by the accused. The tribunal relied on detailed factual money-trail in the original complaint identifying extensive related entities and payments (including an additional payment of Rs. 39.75 crores) and found loans, even if repaid, originated from tainted funds; consequently the attachment was lawful and the appeals were dismissed. - AT
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