Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
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Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Section 20 of the Prevention of Money-Laundering Act does not cause a freezing order to lapse automatically after 180 days where the Adjudicating Authority has authorised retention or continuation within that period. On the facts, the retention order had been passed in time, so the challenge based on the outer-limit argument failed. The Tribunal also found prima facie material, including the appellant's own statement, showing involvement in facilitating false inspection reports, verification of bank guarantees and processing connected proposals, and noted the failure to disclose the source of the funds in the frozen accounts. The challenge to continued retention was rejected and the appeal dismissed.
Section 20 of the Prevention of Money-Laundering Act does not cause a freezing order to lapse automatically after 180 days where the Adjudicating Authority has authorised retention or continuation within that period. On the facts, the retention order had been passed in time, so the challenge based on the outer-limit argument failed. The Tribunal also found prima facie material, including the appellant's own statement, showing involvement in facilitating false inspection reports, verification of bank guarantees and processing connected proposals, and noted the failure to disclose the source of the funds in the frozen accounts. The challenge to continued retention was rejected and the appeal dismissed.
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