Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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...
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The Tribunal held that the 180-day period for provisional attachment was saved by exclusion of the Covid-19 period from 15.03.2020 to 28.02.2022, so the impugned orders were within time. It rejected challenges to maintainability, finding the predicate offence and money-laundering allegations supported by the FIR, ECIR, money trail, statements, and unexplained diversion of funds, while the Supreme Court interim order did not bar attachment proceedings. It further held that the appellants failed to prove a legitimate source for jewellery and immovable properties in family members' names, and that Section 8(3) empowers retention or continuation of freezing without a prior Section 20 order. All appeals were dismissed.
The Tribunal held that the 180-day period for provisional attachment was saved by exclusion of the Covid-19 period from 15.03.2020 to 28.02.2022, so the impugned orders were within time. It rejected challenges to maintainability, finding the predicate offence and money-laundering allegations supported by the FIR, ECIR, money trail, statements, and unexplained diversion of funds, while the Supreme Court interim order did not bar attachment proceedings. It further held that the appellants failed to prove a legitimate source for jewellery and immovable properties in family members' names, and that Section 8(3) empowers retention or continuation of freezing without a prior Section 20 order. All appeals were dismissed.
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