Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Provisional attachment under the 2002 Act can extend to persons not named as accused in the FIR or chargesheet if the property is linked to proceeds of crime and the person is shown as a recipient or holder of such proceeds. The Tribunal rejected the challenge based solely on non-inclusion in the predicate offence. It also held that the appellants failed to prove the lawful source of more than Rs. 10 crore remitted through banking channels and used for property purchases, and that contemporaneous SMS and purchase records supported the money-trail. The plea that some properties were acquired before the murder did not defeat equivalent value attachment, and the attachment was upheld.
Provisional attachment under the 2002 Act can extend to persons not named as accused in the FIR or chargesheet if the property is linked to proceeds of crime and the person is shown as a recipient or holder of such proceeds. The Tribunal rejected the challenge based solely on non-inclusion in the predicate offence. It also held that the appellants failed to prove the lawful source of more than Rs. 10 crore remitted through banking channels and used for property purchases, and that contemporaneous SMS and purchase records supported the money-trail. The plea that some properties were acquired before the murder did not defeat equivalent value attachment, and the attachment was upheld.
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