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 Provisional Attachment Order against property owned by Heera Retail Pvt. Ltd., a group company of the main accused. The appellants' claim based on a civil court decree was rejected as Heera Retail was not party to the civil suit, rendering the decree non-binding on the company. The property had been purchased using proceeds of crime (diverted depositors' funds) prior to the decree. The Tribunal determined that the collusive decree obtained by appellants could not prevail against unchallenged sale deeds executed in favor of the accused's company. The attachment remains valid subject to the Supreme Court's directions regarding realization of investors' dues.
The AT upheld the Provisional Attachment Order against property owned by Heera Retail Pvt. Ltd., a group company of the main accused. The appellants' claim based on a civil court decree was rejected as Heera Retail was not party to the civil suit, rendering the decree non-binding on the company. The property had been purchased using proceeds of crime (diverted depositors' funds) prior to the decree. The Tribunal determined that the collusive decree obtained by appellants could not prevail against unchallenged sale deeds executed in favor of the accused's company. The attachment remains valid subject to the Supreme Court's directions regarding realization of investors' dues.
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