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 PMLA can extend to property of equivalent value where the original proceeds of crime are unavailable, even if the attached property was acquired before the alleged offence; the attachment was upheld on that basis. Pendency of a challenge to the predicate offence before the Supreme Court did not by itself invalidate the attachment, because the predicate offence had not been quashed and the interim stay did not extinguish it. The Tribunal also held that provisional attachment is not confined to a person formally named as an accused in the predicate offence, if the person is otherwise involved in the offence or is a recipient of proceeds of crime. The attachment was sustained, subject to the final outcome before the Supreme Court.
Provisional attachment under PMLA can extend to property of equivalent value where the original proceeds of crime are unavailable, even if the attached property was acquired before the alleged offence; the attachment was upheld on that basis. Pendency of a challenge to the predicate offence before the Supreme Court did not by itself invalidate the attachment, because the predicate offence had not been quashed and the interim stay did not extinguish it. The Tribunal also held that provisional attachment is not confined to a person formally named as an accused in the predicate offence, if the person is otherwise involved in the offence or is a recipient of proceeds of crime. The attachment was sustained, subject to the final outcome before the Supreme Court.
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