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 Appellate Tribunal dismissed the appeal, upholding the attachment of properties under the Prevention of Money Laundering Act (PMLA) 2002. Despite acquittals in some cases, the Enforcement Case Information Report (ECIR) and cognizance of the money laundering offence remained against the accused. The irregular cash deposits in bank accounts, failure to disclose the source of cash used for property acquisitions, and the routing of funds through multiple persons without justification, led the Adjudicating Authority to conclude that the properties were acquired from proceeds of crime. The Income Tax Returns did not sufficiently establish the lawful source of income. The Tribunal found no reason to interfere with the order attaching the properties.
The Appellate Tribunal dismissed the appeal, upholding the attachment of properties under the Prevention of Money Laundering Act (PMLA) 2002. Despite acquittals in some cases, the Enforcement Case Information Report (ECIR) and cognizance of the money laundering offence remained against the accused. The irregular cash deposits in bank accounts, failure to disclose the source of cash used for property acquisitions, and the routing of funds through multiple persons without justification, led the Adjudicating Authority to conclude that the properties were acquired from proceeds of crime. The Income Tax Returns did not sufficiently establish the lawful source of income. The Tribunal found no reason to interfere with the order attaching the properties.
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