Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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A provisional attachment under money laundering law was sustained because the appellants failed to prove the lawful source of the attached properties. The Tribunal found that claims regarding a brother's purchase and gift of a flat, and properties held by the wife, son, and family entities, were unsupported by satisfactory documentary material. Income-tax returns, registered deeds, and assertions of subcontract work were held insufficient where bank entries, summons responses, and proof of actual business activity did not establish genuine acquisition sources. On that basis, the Tribunal accepted that the entities were used to layer and project tainted funds as untainted and found no perversity in the order confirming attachment.
A provisional attachment under money laundering law was sustained because the appellants failed to prove the lawful source of the attached properties. The Tribunal found that claims regarding a brother's purchase and gift of a flat, and properties held by the wife, son, and family entities, were unsupported by satisfactory documentary material. Income-tax returns, registered deeds, and assertions of subcontract work were held insufficient where bank entries, summons responses, and proof of actual business activity did not establish genuine acquisition sources. On that basis, the Tribunal accepted that the entities were used to layer and project tainted funds as untainted and found no perversity in the order confirming attachment.
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