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 dismissed the appeal in money laundering case, holding that where a person possesses assets apparently acquired from proceeds of crime, the burden of proof shifts to the appellant to justify the source of such assets. In cases involving illegal income sources like terrorist funding or drug trafficking, investigation agencies can presume entire assets as proceeds of crime if the individual cannot substantiate legitimate income sources. The tribunal emphasized that non-quantification of exact proceeds does not invalidate the prosecution's case, particularly when unexplained assets suggest criminal origin.
AT dismissed the appeal in money laundering case, holding that where a person possesses assets apparently acquired from proceeds of crime, the burden of proof shifts to the appellant to justify the source of such assets. In cases involving illegal income sources like terrorist funding or drug trafficking, investigation agencies can presume entire assets as proceeds of crime if the individual cannot substantiate legitimate income sources. The tribunal emphasized that non-quantification of exact proceeds does not invalidate the prosecution's case, particularly when unexplained assets suggest criminal origin.
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