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 that ED validly attached properties under Money Laundering Prevention Act. The tribunal found sufficient evidence demonstrating appellants' involvement in proceeds of crime, including property transfers and criminal investigations. Despite arguments regarding legitimate income sources and retrospective application of legal provisions, the court confirmed attachment of properties as proceeds of crime or equivalent value. The decision hinged on three key interpretative limbs of proceeds of crime definition, ultimately supporting ED's position that properties could be attached even if acquired prior to criminal proceedings. The appellants' conduct, including absconding, further substantiated the tribunal's ruling. Appeal was consequently dismissed, upholding ED's original property attachment order.
AT determined that ED validly attached properties under Money Laundering Prevention Act. The tribunal found sufficient evidence demonstrating appellants' involvement in proceeds of crime, including property transfers and criminal investigations. Despite arguments regarding legitimate income sources and retrospective application of legal provisions, the court confirmed attachment of properties as proceeds of crime or equivalent value. The decision hinged on three key interpretative limbs of proceeds of crime definition, ultimately supporting ED's position that properties could be attached even if acquired prior to criminal proceedings. The appellants' conduct, including absconding, further substantiated the tribunal's ruling. Appeal was consequently dismissed, upholding ED's original property attachment order.
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