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 allowed the appeal and set aside the orders of provisional attachment and its confirmation. The accused were discharged from the predicate offence by the Competent Court, and the order attained finality in the absence of a challenge. Since the accused were discharged from the scheduled offence, the impugned orders of provisional attachment and its confirmation could not be sustained under the Prevention of Money Laundering Act, 2002. The attachment of properties belonging to the accused and their entities was questioned, and the Tribunal accepted the argument that when the accused were discharged from the predicate offence, the orders of provisional attachment could not be upheld.
The Appellate Tribunal allowed the appeal and set aside the orders of provisional attachment and its confirmation. The accused were discharged from the predicate offence by the Competent Court, and the order attained finality in the absence of a challenge. Since the accused were discharged from the scheduled offence, the impugned orders of provisional attachment and its confirmation could not be sustained under the Prevention of Money Laundering Act, 2002. The attachment of properties belonging to the accused and their entities was questioned, and the Tribunal accepted the argument that when the accused were discharged from the predicate offence, the orders of provisional attachment could not be upheld.
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