Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Shares held in a demat account were treated as property acquired from proceeds of crime where the appellant, a Data Entry Operator on a modest salary, had received funds from an entity linked to alleged diversion of money and could not substantiate her claim that the transfer was a one-time family medical help. The bank records showed the amount was used to purchase shares of M/s CGPISL, which remained in the demat account. The Appellate Tribunal found no illegality in the provisional attachment merely because the appellant was not named in the FIR and upheld the attachment of the shares. The appeal was dismissed.
Shares held in a demat account were treated as property acquired from proceeds of crime where the appellant, a Data Entry Operator on a modest salary, had received funds from an entity linked to alleged diversion of money and could not substantiate her claim that the transfer was a one-time family medical help. The bank records showed the amount was used to purchase shares of M/s CGPISL, which remained in the demat account. The Appellate Tribunal found no illegality in the provisional attachment merely because the appellant was not named in the FIR and upheld the attachment of the shares. The appeal was dismissed.
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