Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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 money laundering law was sustained where the Tribunal held that the attachment was confined to the accused co-owner's share and did not extend to the non-accused spouse's interest. It further held that property of equivalent value could be attached when the alleged proceeds of crime had been dissipated or were no longer available, and that prior purchase or disclosed source of funds did not defeat such attachment on the facts. The confirmation of the provisional attachment order was therefore upheld and the appeals were dismissed.
Provisional attachment under money laundering law was sustained where the Tribunal held that the attachment was confined to the accused co-owner's share and did not extend to the non-accused spouse's interest. It further held that property of equivalent value could be attached when the alleged proceeds of crime had been dissipated or were no longer available, and that prior purchase or disclosed source of funds did not defeat such attachment on the facts. The confirmation of the provisional attachment order was therefore upheld and the appeals were dismissed.
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