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...
Attachment of property under PMLA is discussed in the context of alleged proceeds of crime arising from scheduled offences, where the Adjudicating Authority issued a show cause notice on the basis of the original complaint, relied-upon documents and statements under section 50, and later confirmed the provisional attachment. The appeals were carried to the Appellate Tribunal under SAFEMA. A specific contention noted in the source is that attachment of property acquired before 01-07-2005, the commencement of PMLA, is not valid in law; the Tribunal is stated to have dealt with that issue along with the other grounds raised.
Attachment of property under PMLA is discussed in the context of alleged proceeds of crime arising from scheduled offences, where the Adjudicating Authority issued a show cause notice on the basis of the original complaint, relied-upon documents and statements under section 50, and later confirmed the provisional attachment. The appeals were carried to the Appellate Tribunal under SAFEMA. A specific contention noted in the source is that attachment of property acquired before 01-07-2005, the commencement of PMLA, is not valid in law; the Tribunal is stated to have dealt with that issue along with the other grounds raised.
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