Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The Tribunal upheld attachment under the PMLA after finding valid service of the show cause notice, complaint and relied upon documents, and therefore no breach of natural justice or denial of hearing. It further held that property attached as proceeds of crime or the value thereof remains liable to attachment even if acquired before the alleged offence period, because the statute treats direct proceeds and their value alike. It also confirmed attachment of assets standing in a spouse's name or jointly held, holding that attachment is not limited to an accused in the scheduled offence but extends to any person involved in activity connected with proceeds of crime. Both appeals were dismissed.
The Tribunal upheld attachment under the PMLA after finding valid service of the show cause notice, complaint and relied upon documents, and therefore no breach of natural justice or denial of hearing. It further held that property attached as proceeds of crime or the value thereof remains liable to attachment even if acquired before the alleged offence period, because the statute treats direct proceeds and their value alike. It also confirmed attachment of assets standing in a spouse's name or jointly held, holding that attachment is not limited to an accused in the scheduled offence but extends to any person involved in activity connected with proceeds of crime. Both appeals were dismissed.
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