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 of fixed deposits was sustained as value of proceeds of crime where the Tribunal found an established fraud in the predicate case and a substantial nexus between the appellant and the accused company through common directorship and shareholding, including the accused company's 49.90% stake. It held that, given the magnitude of the fraud and the absence of available assets of the accused company and its Director, the appellant's deposits could be attached even without direct evidence of transfer of tainted funds from the accused company. The Tribunal rejected release of the deposits on the ground that they came from the appellant's own bank account, and the appeal was dismissed.
Provisional attachment of fixed deposits was sustained as value of proceeds of crime where the Tribunal found an established fraud in the predicate case and a substantial nexus between the appellant and the accused company through common directorship and shareholding, including the accused company's 49.90% stake. It held that, given the magnitude of the fraud and the absence of available assets of the accused company and its Director, the appellant's deposits could be attached even without direct evidence of transfer of tainted funds from the accused company. The Tribunal rejected release of the deposits on the ground that they came from the appellant's own bank account, and the appeal was dismissed.
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