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 AT upheld the attachment of properties acquired prior to the commission of the alleged crime. The proceeds of crime were siphoned off by diverting and layering, thus the property of equivalent value was attached under the second limb of the definition of "proceeds of crime." The provisional attachment order did not lapse due to the intervening Covid-19 period eliminated by the Apex Court. The properties were linked to the proceeds of crime through financial transactions and layering. The scheduled offence was valid as the relevant date was when the tainted property was projected as untainted in 2012, leading to the recording of the money laundering offence. The appeals were dismissed.
The AT upheld the attachment of properties acquired prior to the commission of the alleged crime. The proceeds of crime were siphoned off by diverting and layering, thus the property of equivalent value was attached under the second limb of the definition of "proceeds of crime." The provisional attachment order did not lapse due to the intervening Covid-19 period eliminated by the Apex Court. The properties were linked to the proceeds of crime through financial transactions and layering. The scheduled offence was valid as the relevant date was when the tainted property was projected as untainted in 2012, leading to the recording of the money laundering offence. The appeals were dismissed.
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