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 held that the Provisional Attachment Order for Rs. 2.84 crores against the appellant is set aside, as the funds were legitimately received through banking channels from share transfer to a third party. Regarding the Rs. 11 crores proceeds of crime, the parties agreed to maintain status quo, with property possession unchanged and no alienation permitted until trial conclusion. The attachment order was deemed improper as the appellant demonstrated a valid source of funds through a transparent financial transaction. Appeal partially allowed with specific directives preserving the property's current status pending final judicial determination.
AT held that the Provisional Attachment Order for Rs. 2.84 crores against the appellant is set aside, as the funds were legitimately received through banking channels from share transfer to a third party. Regarding the Rs. 11 crores proceeds of crime, the parties agreed to maintain status quo, with property possession unchanged and no alienation permitted until trial conclusion. The attachment order was deemed improper as the appellant demonstrated a valid source of funds through a transparent financial transaction. Appeal partially allowed with specific directives preserving the property's current status pending final judicial determination.
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