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 examined the attachment of properties allegedly linked to proceeds of crime. The tribunal found no substantive evidence connecting the properties to criminal proceeds. The appellant demonstrated legitimate source of funds through sale of shares in 2009, receiving Rs. 18.87 crores. Properties at A-20 Kailash Colony were legally purchased from M/s Libra Realtors and M/s Dewan Realtors through registered deed in 2015, with full consideration paid via banking channels. The AT concluded the provisional attachment order was incorrectly issued, constituting potential double attachment. Consequently, the tribunal set aside the attachment order, allowing the appellant's appeal and rejecting the respondent's claims of proceeds of crime.
The AT examined the attachment of properties allegedly linked to proceeds of crime. The tribunal found no substantive evidence connecting the properties to criminal proceeds. The appellant demonstrated legitimate source of funds through sale of shares in 2009, receiving Rs. 18.87 crores. Properties at A-20 Kailash Colony were legally purchased from M/s Libra Realtors and M/s Dewan Realtors through registered deed in 2015, with full consideration paid via banking channels. The AT concluded the provisional attachment order was incorrectly issued, constituting potential double attachment. Consequently, the tribunal set aside the attachment order, allowing the appellant's appeal and rejecting the respondent's claims of proceeds of crime.
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