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 money-laundering law was examined on the quantification of proceeds of crime, tracing of tainted funds, and the sufficiency of reasons to believe. The Tribunal upheld the computation, finding that the attachment order explained the basis of recovery and that the appellant's requested deductions were unsupported or already accounted for in the quantified amount. It also accepted that the statutory reverse burden required the person concerned to explain the source of property after notice under Section 8(1), and rejected the challenge under Section 5(1) because the reasons for attachment were reflected in the order and supporting material. The order was treated as speaking, and the appeal was dismissed.
Provisional attachment under money-laundering law was examined on the quantification of proceeds of crime, tracing of tainted funds, and the sufficiency of reasons to believe. The Tribunal upheld the computation, finding that the attachment order explained the basis of recovery and that the appellant's requested deductions were unsupported or already accounted for in the quantified amount. It also accepted that the statutory reverse burden required the person concerned to explain the source of property after notice under Section 8(1), and rejected the challenge under Section 5(1) because the reasons for attachment were reflected in the order and supporting material. The order was treated as speaking, and the appeal was dismissed.
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