Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Provisional attachment of properties held by company officials was sustained where they were found to have actively assisted directors in promoting unlawful preference-share schemes, mobilising public investments and diverting proceeds of the scheduled offence. Recorded statements and charge-sheet material linked the officials to the acquisition of properties in their names. Their claim that the properties were purchased solely from salary and incentives was rejected because the attached value was substantially lower than amounts received from the company. The attachment remains subject to the final outcome of the criminal proceedings.
Provisional attachment of properties held by company officials was sustained where they were found to have actively assisted directors in promoting unlawful preference-share schemes, mobilising public investments and diverting proceeds of the scheduled offence. Recorded statements and charge-sheet material linked the officials to the acquisition of properties in their names. Their claim that the properties were purchased solely from salary and incentives was rejected because the attached value was substantially lower than amounts received from the company. The attachment remains subject to the final outcome of the criminal proceedings.
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