TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Property of equivalent value may be provisionally attached where property directly or indirectly derived from criminal activity is unavailable because it has vanished or been laundered. The phrase "or the value of any such property" operates as an independent limb of the definition of proceeds of crime, permitting attachment of substitute assets of equivalent value. Such assets may include property acquired before the alleged criminal activity and need not have a direct nexus with that activity. Restricting attachment only to directly traceable proceeds would render the equivalent-value limb ineffective and undermine the statutory objective.
Property of equivalent value may be provisionally attached where property directly or indirectly derived from criminal activity is unavailable because it has vanished or been laundered. The phrase "or the value of any such property" operates as an independent limb of the definition of proceeds of crime, permitting attachment of substitute assets of equivalent value. Such assets may include property acquired before the alleged criminal activity and need not have a direct nexus with that activity. Restricting attachment only to directly traceable proceeds would render the equivalent-value limb ineffective and undermine the statutory objective.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4912 
