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 Act was upheld where funds raised by a bitcoin scheme were identified as proceeds of crime and laundered through layered banking transactions, asset purchases and shell entities; the Adjudicating Authority's characterisation of the impugned properties as tainted was supported by admissions and bank-trace analysis, and attachment was confirmed. Attachment was permissible despite the properties being held by persons not yet named as accused where material indicated possession of proceeds. Rapid, unexplained loan repayment was treated as indicative of layering. Death of the principal did not nullify attachment absent a recorded order of abatement; apprehension of alienation justified provisional attachment.
Provisional attachment under the Act was upheld where funds raised by a bitcoin scheme were identified as proceeds of crime and laundered through layered banking transactions, asset purchases and shell entities; the Adjudicating Authority's characterisation of the impugned properties as tainted was supported by admissions and bank-trace analysis, and attachment was confirmed. Attachment was permissible despite the properties being held by persons not yet named as accused where material indicated possession of proceeds. Rapid, unexplained loan repayment was treated as indicative of layering. Death of the principal did not nullify attachment absent a recorded order of abatement; apprehension of alienation justified provisional attachment.
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