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 the PMLA was upheld because the controlling requirement is material showing possession of proceeds of crime linked to a scheduled offence, and the provision is not limited to persons named in the predicate case. The Court accepted that reasons to believe may be based on circumstantial material, including financial patterns, seized documents and Section 50 statements, and held that the burden under Section 24 shifted once the attached property was shown to be involved in money laundering. It also held that proceeds of crime includes value equivalent assets, so properties acquired before the offence period may be attached if the original tainted assets are unavailable. The challenge to the single-member coram was rejected.
Provisional attachment under the PMLA was upheld because the controlling requirement is material showing possession of proceeds of crime linked to a scheduled offence, and the provision is not limited to persons named in the predicate case. The Court accepted that reasons to believe may be based on circumstantial material, including financial patterns, seized documents and Section 50 statements, and held that the burden under Section 24 shifted once the attached property was shown to be involved in money laundering. It also held that proceeds of crime includes value equivalent assets, so properties acquired before the offence period may be attached if the original tainted assets are unavailable. The challenge to the single-member coram was rejected.
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