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 set aside provisional attachment order against appellant company's bank accounts due to violation of natural justice principles. The tribunal found that the appellant was not provided an opportunity of hearing as mandated under Section 8 of the Act of 2002, despite significant allegations of money laundering. Although Wadhawans allegedly exercised control over the company, the court determined that factual issues could not be adequately addressed without proper hearing. The case was remanded to the Adjudicating Authority to issue notice and provide appellant an opportunity to present its case, thereby ensuring procedural fairness in the provisional attachment proceedings.
AT set aside provisional attachment order against appellant company's bank accounts due to violation of natural justice principles. The tribunal found that the appellant was not provided an opportunity of hearing as mandated under Section 8 of the Act of 2002, despite significant allegations of money laundering. Although Wadhawans allegedly exercised control over the company, the court determined that factual issues could not be adequately addressed without proper hearing. The case was remanded to the Adjudicating Authority to issue notice and provide appellant an opportunity to present its case, thereby ensuring procedural fairness in the provisional attachment proceedings.
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