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 attachment of shares in a money laundering case, finding that the appellant routed bribe money through share purchases related to the Agusta Westland transaction. The tribunal determined that the relevant time for assessing money laundering is when the Enforcement Directorate discovers the crime, not the date of the predicate offence. The court emphasized that the appellant's actions involved channelizing proceeds of crime through strategic share acquisitions, thereby establishing a clear money laundering nexus. The evidence demonstrated a deliberate mechanism to transfer illicit funds through equity transactions. Consequently, the tribunal rejected the appellant's challenge to the share attachment, confirming the Enforcement Directorate's actions as legally valid under the Prevention of Money Laundering Act. Appeal dismissed.
The AT upheld the attachment of shares in a money laundering case, finding that the appellant routed bribe money through share purchases related to the Agusta Westland transaction. The tribunal determined that the relevant time for assessing money laundering is when the Enforcement Directorate discovers the crime, not the date of the predicate offence. The court emphasized that the appellant's actions involved channelizing proceeds of crime through strategic share acquisitions, thereby establishing a clear money laundering nexus. The evidence demonstrated a deliberate mechanism to transfer illicit funds through equity transactions. Consequently, the tribunal rejected the appellant's challenge to the share attachment, confirming the Enforcement Directorate's actions as legally valid under the Prevention of Money Laundering Act. Appeal dismissed.
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