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...
The Tribunal interpreted "proceeds of crime" to include not only property directly or indirectly derived from a scheduled offence, but also property of equivalent value where the actual tainted property is unavailable. On that construction, provisional attachment can extend to immovable properties acquired before the check-period or even before commission of the offence, because the relevant question is whether equivalent-value attachment secures quantified proceeds of crime. The check-period used for assessing disproportionate assets was held to be distinct from the period relevant to attachment. As the value of the attached properties remained below the quantified proceeds of crime, the confirmation of provisional attachment was upheld.
The Tribunal interpreted "proceeds of crime" to include not only property directly or indirectly derived from a scheduled offence, but also property of equivalent value where the actual tainted property is unavailable. On that construction, provisional attachment can extend to immovable properties acquired before the check-period or even before commission of the offence, because the relevant question is whether equivalent-value attachment secures quantified proceeds of crime. The check-period used for assessing disproportionate assets was held to be distinct from the period relevant to attachment. As the value of the attached properties remained below the quantified proceeds of crime, the confirmation of provisional attachment was upheld.
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