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...
Provisional attachment under the Prevention of Money Laundering regime may be ordered against a person or entity in possession of proceeds of crime even if not formally accused; the tribunal applied the principles that challenge to the prosecution complaint does not suspend attachment proceedings while criminal proceedings remain pending and that existence of parallel FIRs sustaining the scheduled offence permits continuation. The Adjudicating Authority's confirmation of provisional attachment was upheld on material showing receipt of proceeds by the appellants, and the appeals were dismissed for lack of merit.
Provisional attachment under the Prevention of Money Laundering regime may be ordered against a person or entity in possession of proceeds of crime even if not formally accused; the tribunal applied the principles that challenge to the prosecution complaint does not suspend attachment proceedings while criminal proceedings remain pending and that existence of parallel FIRs sustaining the scheduled offence permits continuation. The Adjudicating Authority's confirmation of provisional attachment was upheld on material showing receipt of proceeds by the appellants, and the appeals were dismissed for lack of merit.
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