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 upheld seizure and freezing order against gaming company for alleged money laundering through unauthorized digital transactions. The company collected approximately Rs.2850 crore, transmitting Rs.2320 crore outside India, without transparent disclosure of fund sources. ED's reasons to believe under Section 20(1) were legally recorded, and the Adjudicating Authority found substantial evidence of potential financial irregularities. The order of seizure and property retention was justified based on ongoing investigations, API integration with game platforms, and suspicious financial movements. The appeal was dismissed, with final determination of criminal culpability reserved for the Trial Court, maintaining the provisional seizure order's validity pending full judicial review.
AT upheld seizure and freezing order against gaming company for alleged money laundering through unauthorized digital transactions. The company collected approximately Rs.2850 crore, transmitting Rs.2320 crore outside India, without transparent disclosure of fund sources. ED's reasons to believe under Section 20(1) were legally recorded, and the Adjudicating Authority found substantial evidence of potential financial irregularities. The order of seizure and property retention was justified based on ongoing investigations, API integration with game platforms, and suspicious financial movements. The appeal was dismissed, with final determination of criminal culpability reserved for the Trial Court, maintaining the provisional seizure order's validity pending full judicial review.
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