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 affirmed provisional attachment of properties mortgaged by appellant banks in money laundering case. The tribunal recognized potential collusion between bank officials and loan recipients during 2010-2017. Banks were permitted to file claims under PMLA sections 8(5) to 8(8), with liberty to seek property auction and proportionate distribution of outstanding liabilities. The Adjudicating Authority's reasonable belief based on recorded statements and documents substantiated the provisional attachment order. Excess auction proceeds will be deposited as FDR with ED pending trial outcome. Appeal was disposed of, maintaining the original attachment order.
AT affirmed provisional attachment of properties mortgaged by appellant banks in money laundering case. The tribunal recognized potential collusion between bank officials and loan recipients during 2010-2017. Banks were permitted to file claims under PMLA sections 8(5) to 8(8), with liberty to seek property auction and proportionate distribution of outstanding liabilities. The Adjudicating Authority's reasonable belief based on recorded statements and documents substantiated the provisional attachment order. Excess auction proceeds will be deposited as FDR with ED pending trial outcome. Appeal was disposed of, maintaining the original attachment order.
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