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...
Challenge to seizure and retention of cash during search was considered on three dominant issues: whether a predicate offence for money laundering existed, whether reasons to believe and relied documents were furnished, and whether recorded admissions and bank/cash ledgers substantiated source of funds. The Tribunal concluded that the FIRs and investigations disclosed offences underpinning a predicate offence, that the reasons to believe and relied documents were served to the appellants, and that the appellants' explanations failed in view of withdrawal patterns, ledger entries, bank records described as licence receipts and recorded admissions; accordingly seizure and retention were upheld pending trial.
Challenge to seizure and retention of cash during search was considered on three dominant issues: whether a predicate offence for money laundering existed, whether reasons to believe and relied documents were furnished, and whether recorded admissions and bank/cash ledgers substantiated source of funds. The Tribunal concluded that the FIRs and investigations disclosed offences underpinning a predicate offence, that the reasons to believe and relied documents were served to the appellants, and that the appellants' explanations failed in view of withdrawal patterns, ledger entries, bank records described as licence receipts and recorded admissions; accordingly seizure and retention were upheld pending trial.
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