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...
Provisional attachment under the PMLA was upheld because investigative material furnished a reason to believe that the appellant participated in converting demonetized currency into gold/bullion, establishing a proximate link between seized currency and proceeds of crime; absence of the appellant's name in the FIR/ECIR did not bar attachment since PMLA proceedings depend on independent investigative material and statements recorded during the probe; attachment may extend to equivalent value of proceeds even where property was acquired earlier, and the prima facie case met the statutory threshold for sustaining provisional attachment.
Provisional attachment under the PMLA was upheld because investigative material furnished a reason to believe that the appellant participated in converting demonetized currency into gold/bullion, establishing a proximate link between seized currency and proceeds of crime; absence of the appellant's name in the FIR/ECIR did not bar attachment since PMLA proceedings depend on independent investigative material and statements recorded during the probe; attachment may extend to equivalent value of proceeds even where property was acquired earlier, and the prima facie case met the statutory threshold for sustaining provisional attachment.
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