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 adjudicated a money laundering case involving illegal coal excavation and theft from a leasehold area. The tribunal rejected appellants' challenge to provisional attachment orders, finding prima facie evidence of money laundering through shell companies. Witness statements under Section 50 of PMLA 2002, corroborated by joint vigilance inspections revealing illegal equipment and coal recovery, substantiated the allegations. The appellants failed to demonstrate legitimate income sources, with funds channeled through non-existent companies. The tribunal concluded that respondents' actions were legally sound, and no procedural irregularities warranted interference. Consequently, the appeal was dismissed, upholding the provisional attachment of appellants' properties.
AT adjudicated a money laundering case involving illegal coal excavation and theft from a leasehold area. The tribunal rejected appellants' challenge to provisional attachment orders, finding prima facie evidence of money laundering through shell companies. Witness statements under Section 50 of PMLA 2002, corroborated by joint vigilance inspections revealing illegal equipment and coal recovery, substantiated the allegations. The appellants failed to demonstrate legitimate income sources, with funds channeled through non-existent companies. The tribunal concluded that respondents' actions were legally sound, and no procedural irregularities warranted interference. Consequently, the appeal was dismissed, upholding the provisional attachment of appellants' properties.
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