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 affirmed the Provisional Attachment Order (PAO) in a money laundering case involving illegal wildlife trade and ivory trafficking. The tribunal held that properties acquired prior to the criminal offense can be attached when proceeds of crime are unavailable or partially traceable. In this instance, the appellant's involvement was established through ivory recovery, statements under Section 50 of PMLA, 2002, and prima facie evidence of criminal proceeds exceeding Rs. 120 lakhs. The tribunal concluded that the appellant was guilty under Section 3 of PMLA, 2002, and confirmed the attachment of equivalent property value. The appeal was consequently dismissed.
The AT affirmed the Provisional Attachment Order (PAO) in a money laundering case involving illegal wildlife trade and ivory trafficking. The tribunal held that properties acquired prior to the criminal offense can be attached when proceeds of crime are unavailable or partially traceable. In this instance, the appellant's involvement was established through ivory recovery, statements under Section 50 of PMLA, 2002, and prima facie evidence of criminal proceeds exceeding Rs. 120 lakhs. The tribunal concluded that the appellant was guilty under Section 3 of PMLA, 2002, and confirmed the attachment of equivalent property value. The appeal was consequently dismissed.
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