Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Provisional attachment under the second proviso to section 5(1) is upheld where the officer records specific reasons to believe non-attachment would frustrate proceedings; the commentary rejects the appellant's excessive-attachment claim, noting FIR allegations are investigatory starting points and quantum of proceeds requires separate ED inquiry. The reverse burden under section 8(1) obliges the person served to substantiate lawful sources for attached property; failure to produce documentary evidence permits treating the asset as proceeds of crime. Income tax filings declaring tainted receipts do not negate PMLA liability. The article concludes the respondent established a money trail and the attachment and proposed confiscation stand undisplaced.
Provisional attachment under the second proviso to section 5(1) is upheld where the officer records specific reasons to believe non-attachment would frustrate proceedings; the commentary rejects the appellant's excessive-attachment claim, noting FIR allegations are investigatory starting points and quantum of proceeds requires separate ED inquiry. The reverse burden under section 8(1) obliges the person served to substantiate lawful sources for attached property; failure to produce documentary evidence permits treating the asset as proceeds of crime. Income tax filings declaring tainted receipts do not negate PMLA liability. The article concludes the respondent established a money trail and the attachment and proposed confiscation stand undisplaced.
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