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 upheld the provisional attachment order against the appellant, finding insufficient evidence to substantiate the source of Rs. 4.05 crores. Despite claims of income from salary and property sale, the appellant failed to provide credible documentation supporting the fund's origin. The tribunal noted suspicious cash deposits, undisclosed property transactions, and alleged recruitment bribery. The court determined the funds were proceeds of crime under money laundering statutes, rejecting the appellant's explanations as untrustworthy. Consequently, the provisional attachment order was confirmed, and the appeal was dismissed.
AT upheld the provisional attachment order against the appellant, finding insufficient evidence to substantiate the source of Rs. 4.05 crores. Despite claims of income from salary and property sale, the appellant failed to provide credible documentation supporting the fund's origin. The tribunal noted suspicious cash deposits, undisclosed property transactions, and alleged recruitment bribery. The court determined the funds were proceeds of crime under money laundering statutes, rejecting the appellant's explanations as untrustworthy. Consequently, the provisional attachment order was confirmed, and the appeal was dismissed.
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