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 adjudicated a money laundering case involving seizure of office files and digital evidence under PMLA. The tribunal directed ED to release unreferenced seized documents to the appellant, while permitting ED to retain photocopies for potential future investigations. ED must obtain appellant's endorsement on photocopies regarding authenticity. Documents already incorporated in criminal proceedings or chargesheet remain non-returnable. The appellant must provide an affidavit undertaking not to challenge photocopy authenticity. The order mandates compliance within six months post statutory limitation period for high court appeals, effectively resolving the evidentiary dispute without examining case merits.
AT adjudicated a money laundering case involving seizure of office files and digital evidence under PMLA. The tribunal directed ED to release unreferenced seized documents to the appellant, while permitting ED to retain photocopies for potential future investigations. ED must obtain appellant's endorsement on photocopies regarding authenticity. Documents already incorporated in criminal proceedings or chargesheet remain non-returnable. The appellant must provide an affidavit undertaking not to challenge photocopy authenticity. The order mandates compliance within six months post statutory limitation period for high court appeals, effectively resolving the evidentiary dispute without examining case merits.
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