Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
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...
Under the Prevention of Money Laundering Act, provisional attachment may extend to buildings and infrastructure representing the value of proceeds of crime where material establishes a rational nexus between alleged scheduled offences, the generation of criminal proceeds and their use in creating the property. Money-laundering does not depend on the commercial success or failure of the underlying enterprise; the relevant inquiry is whether property was directly or indirectly derived or obtained through criminal activity relating to a scheduled offence. Attachment may apply to persons connected with proceeds of crime even if they are not accused in the scheduled offence. Disputes concerning reciprocal obligations under a memorandum of understanding do not determine attachment proceedings.
Under the Prevention of Money Laundering Act, provisional attachment may extend to buildings and infrastructure representing the value of proceeds of crime where material establishes a rational nexus between alleged scheduled offences, the generation of criminal proceeds and their use in creating the property. Money-laundering does not depend on the commercial success or failure of the underlying enterprise; the relevant inquiry is whether property was directly or indirectly derived or obtained through criminal activity relating to a scheduled offence. Attachment may apply to persons connected with proceeds of crime even if they are not accused in the scheduled offence. Disputes concerning reciprocal obligations under a memorandum of understanding do not determine attachment proceedings.
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