Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
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Provisional attachment of alleged proceeds of crime represented as long-term capital gains from share sales continued because the share purchasers appeared to have been funded from sources other than their own. Funds were routed through banking channels to acquire shares in non-functioning companies at highly appreciated prices, without an apparent commercial basis for the valuation. The investment explanation was treated as unconvincing, including in light of the appellant's role in the trust operating the university. As the scheduled-offence and money-laundering trials remained pending, the attachment was retained to secure the alleged proceeds of crime until trial conclusion.
Provisional attachment of alleged proceeds of crime represented as long-term capital gains from share sales continued because the share purchasers appeared to have been funded from sources other than their own. Funds were routed through banking channels to acquire shares in non-functioning companies at highly appreciated prices, without an apparent commercial basis for the valuation. The investment explanation was treated as unconvincing, including in light of the appellant's role in the trust operating the university. As the scheduled-offence and money-laundering trials remained pending, the attachment was retained to secure the alleged proceeds of crime until trial conclusion.
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