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...
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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 upheld the provisional attachment order under PMLA, dismissing appellants' challenge. The tribunal found authorities had properly recorded satisfaction under sections 5 and 8, rejecting claims of procedural violations. Properties purchased before the predicate offense were validly attached as representing proceeds of crime value. Despite appellants' claim of utilizing funds for legitimate business purposes in April 2008, AT maintained attachment was justified while criminal proceedings remained pending. Properties could be attached regardless of whether appellants were charged with scheduled offenses, as long as evidence showed proceeds of crime connection. The retrospective application of PMLA was deemed constitutionally valid as attachment constitutes civil action. Canara Bank's interests were noted as resolved following loan closure.
AT upheld the provisional attachment order under PMLA, dismissing appellants' challenge. The tribunal found authorities had properly recorded satisfaction under sections 5 and 8, rejecting claims of procedural violations. Properties purchased before the predicate offense were validly attached as representing proceeds of crime value. Despite appellants' claim of utilizing funds for legitimate business purposes in April 2008, AT maintained attachment was justified while criminal proceedings remained pending. Properties could be attached regardless of whether appellants were charged with scheduled offenses, as long as evidence showed proceeds of crime connection. The retrospective application of PMLA was deemed constitutionally valid as attachment constitutes civil action. Canara Bank's interests were noted as resolved following loan closure.
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