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 determined appellant engaged in money laundering through criminal conspiracy while employed as Senior Manager at MECON Ltd. Appellant received Rs. 1,65,45,000 from two companies through multiple bank accounts of relatives and friends. Forensic analysis revealed suspicious property transactions, including sale of Tritiya Tower property at inflated rates without justifiable source of funds. Appellant failed to produce credible evidence substantiating legitimate sale transactions. Provisional attachment order of properties was upheld as legally valid. The appellate tribunal conclusively found no procedural irregularities in the original attachment order and consequently dismissed the appeal, maintaining the provisional attachment of appellant's properties.
AT determined appellant engaged in money laundering through criminal conspiracy while employed as Senior Manager at MECON Ltd. Appellant received Rs. 1,65,45,000 from two companies through multiple bank accounts of relatives and friends. Forensic analysis revealed suspicious property transactions, including sale of Tritiya Tower property at inflated rates without justifiable source of funds. Appellant failed to produce credible evidence substantiating legitimate sale transactions. Provisional attachment order of properties was upheld as legally valid. The appellate tribunal conclusively found no procedural irregularities in the original attachment order and consequently dismissed the appeal, maintaining the provisional attachment of appellant's properties.
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