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...
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PMLA attachment of a company's properties requires a demonstrated nexus between the alleged proceeds of crime and a scheduled offence. Share application money linked to coal-block allocation could not be treated as proceeds of crime where investor statements did not show that the allocation induced the investments, and allegations of director-controlled entities or public-fund involvement lacked supporting particulars, complaint or FIR. The attachment confirmation was set aside for the appellant company because the requisite connection between the funds and the scheduled offence was not established.
PMLA attachment of a company's properties requires a demonstrated nexus between the alleged proceeds of crime and a scheduled offence. Share application money linked to coal-block allocation could not be treated as proceeds of crime where investor statements did not show that the allocation induced the investments, and allegations of director-controlled entities or public-fund involvement lacked supporting particulars, complaint or FIR. The attachment confirmation was set aside for the appellant company because the requisite connection between the funds and the scheduled offence was not established.
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