Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Proceedings under the PMLA operate independently of scheduled-offence criminal proceedings, so provisional attachment may target persons not named in the FIR/ECIR where authorised officers possess material indicating possession or processing of proceeds of crime; absence of a named reference does not bar attachment. A preventive provisional attachment requires only 'reason to believe' and was sustained on prima facie material showing routing of demonetised currency, RTGS credits and layering/integration into bank accounts. Voluntary declaration or tax payment under PMGKY does not confer immunity from PMLA action; authorities may attach property of equivalent value where original proceeds are untraceable.
Proceedings under the PMLA operate independently of scheduled-offence criminal proceedings, so provisional attachment may target persons not named in the FIR/ECIR where authorised officers possess material indicating possession or processing of proceeds of crime; absence of a named reference does not bar attachment. A preventive provisional attachment requires only 'reason to believe' and was sustained on prima facie material showing routing of demonetised currency, RTGS credits and layering/integration into bank accounts. Voluntary declaration or tax payment under PMGKY does not confer immunity from PMLA action; authorities may attach property of equivalent value where original proceeds are untraceable.
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