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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Appellants challenged the provisional attachment of their immovable and movable properties under the Prevention of Money Laundering Act (PMLA), alleging lack of evidence that the properties were acquired from proceeds of crime. The court held that the appellants failed to provide reliable proof of their claimed sources of income like agriculture, rent, and contracts to explain the actual purchase consideration. Income tax returns filed belatedly after investigations were insufficient. Under PMLA, the burden lies on the noticee to show the sources of income/assets. The presumptions u/ss 23 and 24 operate against the appellants. The court rejected the contention that the definition of "proceeds of crime" was not considered, as the pre-amendment definition covered any property derived directly/indirectly from criminal activity related to scheduled offences. The attached property's value was rightly determined as Rs. 60,00,000/-, not Rs. 4,37,500/-. Finding no reason to interfere, the Appellate Tribunal dismissed the appeal.
Appellants challenged the provisional attachment of their immovable and movable properties under the Prevention of Money Laundering Act (PMLA), alleging lack of evidence that the properties were acquired from proceeds of crime. The court held that the appellants failed to provide reliable proof of their claimed sources of income like agriculture, rent, and contracts to explain the actual purchase consideration. Income tax returns filed belatedly after investigations were insufficient. Under PMLA, the burden lies on the noticee to show the sources of income/assets. The presumptions u/ss 23 and 24 operate against the appellants. The court rejected the contention that the definition of "proceeds of crime" was not considered, as the pre-amendment definition covered any property derived directly/indirectly from criminal activity related to scheduled offences. The attached property's value was rightly determined as Rs. 60,00,000/-, not Rs. 4,37,500/-. Finding no reason to interfere, the Appellate Tribunal dismissed the appeal.
Note: It is a system-generated summary and is for quick reference only.