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 held that provisional attachment under PMLA is valid despite multiple challenges. The property can be attached even though the appellant was not charged with predicate offences, and the purchase occurred after the alleged crime period. The tribunal rejected the appellant's claim of funds originating from her daughter, finding insufficient documentary evidence to prove legitimate source. The attachment was upheld based on the continuing nature of money laundering offences, emphasizing that proceeds of crime can be seized when discovered, irrespective of the original transaction timeline. Appeal dismissed in favor of ED.
AT held that provisional attachment under PMLA is valid despite multiple challenges. The property can be attached even though the appellant was not charged with predicate offences, and the purchase occurred after the alleged crime period. The tribunal rejected the appellant's claim of funds originating from her daughter, finding insufficient documentary evidence to prove legitimate source. The attachment was upheld based on the continuing nature of money laundering offences, emphasizing that proceeds of crime can be seized when discovered, irrespective of the original transaction timeline. Appeal dismissed in favor of ED.
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