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 appellant's property despite being issued 190 days after the PAO, as the intervening COVID-19 period (15.03.2020 to 28.02.2022) was properly excluded per SC's suo moto order. The tribunal confirmed that properties can be attached even when held by non-accused individuals who possess proceeds of crime, following Vijay Madanlal Choudhary. The appellant failed to prove legitimate cash payment of 14,00,000 to the main accused, while evidence showed the appellant received 5,00,000 and an RTGS transfer of 14,00,000 from the accused, which was subsequently transferred to a company owned by the same accused-establishing the appellant's role in layering and laundering proceeds of crime. Appeal dismissed.
The AT upheld the provisional attachment order against appellant's property despite being issued 190 days after the PAO, as the intervening COVID-19 period (15.03.2020 to 28.02.2022) was properly excluded per SC's suo moto order. The tribunal confirmed that properties can be attached even when held by non-accused individuals who possess proceeds of crime, following Vijay Madanlal Choudhary. The appellant failed to prove legitimate cash payment of 14,00,000 to the main accused, while evidence showed the appellant received 5,00,000 and an RTGS transfer of 14,00,000 from the accused, which was subsequently transferred to a company owned by the same accused-establishing the appellant's role in layering and laundering proceeds of crime. Appeal dismissed.
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