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 property attachment under Prevention of Money-Laundering Act, finding that inherited or acquired property predating the scheduled offence can be attached as equivalent value of proceeds of crime. Despite a delay of over ten years since the initial FIR, the tribunal rejected appellant's challenge, relying on SC's interpretation in Vijay Madanlal Choudhary case. The attachment was validated under the second limb of "proceeds of crime" definition, even when original criminal proceeds were unavailable. Consequently, the appeal was dismissed, affirming ED's authority to attach property of equivalent value linked to alleged money laundering activities.
AT upheld property attachment under Prevention of Money-Laundering Act, finding that inherited or acquired property predating the scheduled offence can be attached as equivalent value of proceeds of crime. Despite a delay of over ten years since the initial FIR, the tribunal rejected appellant's challenge, relying on SC's interpretation in Vijay Madanlal Choudhary case. The attachment was validated under the second limb of "proceeds of crime" definition, even when original criminal proceeds were unavailable. Consequently, the appeal was dismissed, affirming ED's authority to attach property of equivalent value linked to alleged money laundering activities.
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