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's property attachment was valid under PMLA. The tribunal held that properties can be considered proceeds of crime even if acquired prior to predicate offence, based on appellants' habitual criminal involvement and inability to prove legitimate income source. Appellants failed to discharge burden of proof under Section 24 regarding legal acquisition of assets. The tribunal rejected arguments challenging ED's power to provisionally attach properties before criminal conviction, emphasizing PMLA's objective of preventing asset dissipation. Consequently, the appellate tribunal dismissed the appeal, upholding ED's attachment of properties as proceeds of crime.
AT determined that ED's property attachment was valid under PMLA. The tribunal held that properties can be considered proceeds of crime even if acquired prior to predicate offence, based on appellants' habitual criminal involvement and inability to prove legitimate income source. Appellants failed to discharge burden of proof under Section 24 regarding legal acquisition of assets. The tribunal rejected arguments challenging ED's power to provisionally attach properties before criminal conviction, emphasizing PMLA's objective of preventing asset dissipation. Consequently, the appellate tribunal dismissed the appeal, upholding ED's attachment of properties as proceeds of crime.
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