Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
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Provisional attachment of cash as proceeds of crime requires a demonstrated nexus between the property and the scheduled offence. Evidence of a double-trip mechanism, supported by the truck driver's statement, showed excise-duty evasion through repeated use of transport documents. The warehouse owner did not independently corroborate the claimed bank withdrawal or receipts from traders; a cash book retained in the owner's custody lacked independent evidentiary value. The absence of bank records, investigative material, and increased declared income established the nexus between the seized cash and illicit country-liquor transactions, so the cash was treated as proceeds of crime and the attachment remained in force.
Provisional attachment of cash as proceeds of crime requires a demonstrated nexus between the property and the scheduled offence. Evidence of a double-trip mechanism, supported by the truck driver's statement, showed excise-duty evasion through repeated use of transport documents. The warehouse owner did not independently corroborate the claimed bank withdrawal or receipts from traders; a cash book retained in the owner's custody lacked independent evidentiary value. The absence of bank records, investigative material, and increased declared income established the nexus between the seized cash and illicit country-liquor transactions, so the cash was treated as proceeds of crime and the attachment remained in force.
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