Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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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