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 Bank's challenge to property attachment under Prevention of Money Laundering Act (PMLA). Despite Bank's prior mortgage rights and claim as fraud victim, AT upheld attachment order by Enforcement Directorate under Section 5 of PMLA. Following precedent in JM Financial Asset Reconstruction case, AT determined that mortgage status alone insufficient to override PMLA attachment. Bank's rights remain protected under Section 8(8) of PMLA, allowing pursuit of claims within statutory framework. Property attachment stands valid without affecting underlying title until formal confiscation. Bank retains right to pursue remedies under PMLA provisions. Appeal dismissed with no interference in attachment order.
AT ruled against Bank's challenge to property attachment under Prevention of Money Laundering Act (PMLA). Despite Bank's prior mortgage rights and claim as fraud victim, AT upheld attachment order by Enforcement Directorate under Section 5 of PMLA. Following precedent in JM Financial Asset Reconstruction case, AT determined that mortgage status alone insufficient to override PMLA attachment. Bank's rights remain protected under Section 8(8) of PMLA, allowing pursuit of claims within statutory framework. Property attachment stands valid without affecting underlying title until formal confiscation. Bank retains right to pursue remedies under PMLA provisions. Appeal dismissed with no interference in attachment order.
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