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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The case involves a challenge to a seizure order issued u/s 8(3) of PMLA 2002. The investigation, which should have been completed within 365 days as per Section 8(3)(a) of the Act, has not been concluded. The court held that since the investigation has not been completed, the order of seizure cannot continue. It was noted that if the investigation is not completed within the specified time frame, the attachment or seizure would lapse. Therefore, the impugned seizure order by the Adjudicating Authority was set aside, and the appeal was allowed by the Appellate Tribunal.
The case involves a challenge to a seizure order issued u/s 8(3) of PMLA 2002. The investigation, which should have been completed within 365 days as per Section 8(3)(a) of the Act, has not been concluded. The court held that since the investigation has not been completed, the order of seizure cannot continue. It was noted that if the investigation is not completed within the specified time frame, the attachment or seizure would lapse. Therefore, the impugned seizure order by the Adjudicating Authority was set aside, and the appeal was allowed by the Appellate Tribunal.
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