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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AT ruled against double seizure of bank lockers and gold in a money laundering case. The lockers (no. 86 and 96) were already under CBI custody, making subsequent seizure under PMLA Section 17(1) unjustified as there was no risk of concealment. Regarding 3.2kg gold, seizure was invalidated based on CBDT guidelines allowing women to possess specified quantities (500g for married, 250g for unmarried). AT held that properties under one authority's seizure cannot be re-seized by another unless released by the initial authority. The respondent retains right to fresh seizure upon CBI's release. The impugned order was partially modified, and appeal disposed of accordingly.
AT ruled against double seizure of bank lockers and gold in a money laundering case. The lockers (no. 86 and 96) were already under CBI custody, making subsequent seizure under PMLA Section 17(1) unjustified as there was no risk of concealment. Regarding 3.2kg gold, seizure was invalidated based on CBDT guidelines allowing women to possess specified quantities (500g for married, 250g for unmarried). AT held that properties under one authority's seizure cannot be re-seized by another unless released by the initial authority. The respondent retains right to fresh seizure upon CBI's release. The impugned order was partially modified, and appeal disposed of accordingly.
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