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 ruled that the ED's attachment of properties beyond the value of seized gold was unjustified. The scheduled offences under Customs Act Sections 135(1)(a)(i)(A) and 135(1)(b)(i)(A) related solely to foreign gold valued at 13.56 crores, which was already seized by DRI and subsequently attached by ED. Following Vijay Madanlal Choudhary, the ED could not presume additional scheduled offences without evidence, nor attach property exceeding the value of identified proceeds of crime. While unexplained investments might warrant action under tax laws, PMLA proceedings cannot be initiated based on mere assumptions that assets exceeding known income sources derived from scheduled offences. The appeal was disposed of accordingly.
The AT ruled that the ED's attachment of properties beyond the value of seized gold was unjustified. The scheduled offences under Customs Act Sections 135(1)(a)(i)(A) and 135(1)(b)(i)(A) related solely to foreign gold valued at 13.56 crores, which was already seized by DRI and subsequently attached by ED. Following Vijay Madanlal Choudhary, the ED could not presume additional scheduled offences without evidence, nor attach property exceeding the value of identified proceeds of crime. While unexplained investments might warrant action under tax laws, PMLA proceedings cannot be initiated based on mere assumptions that assets exceeding known income sources derived from scheduled offences. The appeal was disposed of accordingly.
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