Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Provisional attachment under the anti-money laundering framework was partly invalidated where the Tribunal found no foundational material to show that pre-existing commercial agreements were designed to layer later proceeds of crime or could be retrospectively treated as commercially irrational or inter-connected transactions under Section 23. Attachment based on the first and second transactions was therefore set aside. By contrast, the Tribunal accepted that a delayed payment linked to the dairy sale arrangement was not credibly explained as a later adjustment against other dealings, and sustained attachment to the equivalent value of that amount. The appeals were thus partly allowed, with attachment continuing only to the specified extent.
Provisional attachment under the anti-money laundering framework was partly invalidated where the Tribunal found no foundational material to show that pre-existing commercial agreements were designed to layer later proceeds of crime or could be retrospectively treated as commercially irrational or inter-connected transactions under Section 23. Attachment based on the first and second transactions was therefore set aside. By contrast, the Tribunal accepted that a delayed payment linked to the dairy sale arrangement was not credibly explained as a later adjustment against other dealings, and sustained attachment to the equivalent value of that amount. The appeals were thus partly allowed, with attachment continuing only to the specified extent.
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