Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Proceeds of crime includes the value of tainted property and its equivalent, permitting provisional attachment even if the property holder is not accused; the tribunal applied the 'value of any such property' limb and treated bank deposits, confessional statements and corroborative seizures as sufficient material to form 'reason to believe', rejecting explanations of family transactions. The adjudicatory finding that unexplained income, expenditure and investments, together with seized cash and gold and transactional patterns, justified confirmation of provisional attachment was sustained and the appeal dismissed for lack of merit.
Proceeds of crime includes the value of tainted property and its equivalent, permitting provisional attachment even if the property holder is not accused; the tribunal applied the 'value of any such property' limb and treated bank deposits, confessional statements and corroborative seizures as sufficient material to form 'reason to believe', rejecting explanations of family transactions. The adjudicatory finding that unexplained income, expenditure and investments, together with seized cash and gold and transactional patterns, justified confirmation of provisional attachment was sustained and the appeal dismissed for lack of merit.
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