Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Money-laundering is treated as an independent and continuing offence, so attachment under the PMLA turns on the date when proceeds of crime are possessed, concealed, used, or projected as untainted property, not on the date of the loan or predicate offence. The definition of proceeds of crime was read to include equivalent value property, allowing attachment of assets acquired earlier when traced tainted property is unavailable. Settlement of bank dues did not displace attachment while the predicate offence remained pending, and property could be attached in the hands of third parties, including a wife or children, if it represented proceeds of crime. The attachment was upheld in full.
Money-laundering is treated as an independent and continuing offence, so attachment under the PMLA turns on the date when proceeds of crime are possessed, concealed, used, or projected as untainted property, not on the date of the loan or predicate offence. The definition of proceeds of crime was read to include equivalent value property, allowing attachment of assets acquired earlier when traced tainted property is unavailable. Settlement of bank dues did not displace attachment while the predicate offence remained pending, and property could be attached in the hands of third parties, including a wife or children, if it represented proceeds of crime. The attachment was upheld in full.
Note: It is a system-generated summary and is for quick reference only.