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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
AT upheld provisional attachment of properties under PMLA related to environmental violations involving illegal waste disposal. The tribunal found no procedural irregularities in the attachment order, affirming that: (a) property mortgage to financial institution can co-exist with PMLA attachment, (b) evidentiary documents seized during investigation were appropriately handled, and (c) technical omissions do not invalidate proceedings. The court emphasized that the investigating authority has discretion in selecting documentary evidence, and the attachment was justified based on proceeds of crime originating from environmental law violations. Appeal against the attachment order was comprehensively dismissed, maintaining the provisional attachment of properties.
AT upheld provisional attachment of properties under PMLA related to environmental violations involving illegal waste disposal. The tribunal found no procedural irregularities in the attachment order, affirming that: (a) property mortgage to financial institution can co-exist with PMLA attachment, (b) evidentiary documents seized during investigation were appropriately handled, and (c) technical omissions do not invalidate proceedings. The court emphasized that the investigating authority has discretion in selecting documentary evidence, and the attachment was justified based on proceeds of crime originating from environmental law violations. Appeal against the attachment order was comprehensively dismissed, maintaining the provisional attachment of properties.
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