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 allowed the appeal, finding that the appellant bank had restored Rs. 25 Crore to the complainant with interest, and the Sessions Court had previously ordered defreezing of eleven bank accounts. The tribunal held that attachment under PMLA is designed to prevent concealment of proceeds of crime, but where the actual owner has compensated the victim, such attachment may be reconsidered. The ED's appropriated funds in FDRs were ordered released to the appellant bank. The ruling emphasized that the decision would not prejudice ongoing criminal proceedings, preserving all parties' rights in subsequent legal actions.
AT allowed the appeal, finding that the appellant bank had restored Rs. 25 Crore to the complainant with interest, and the Sessions Court had previously ordered defreezing of eleven bank accounts. The tribunal held that attachment under PMLA is designed to prevent concealment of proceeds of crime, but where the actual owner has compensated the victim, such attachment may be reconsidered. The ED's appropriated funds in FDRs were ordered released to the appellant bank. The ruling emphasized that the decision would not prejudice ongoing criminal proceedings, preserving all parties' rights in subsequent legal actions.
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