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 of four immovable properties under PMLA was valid. Despite three properties being acquired prior to the scheduled offence and one property acquired post-offence period, ED demonstrated sufficient grounds for attachment. The tribunal found appellant received Rs. 20 lakhs from proceeds of crime, rendering properties attachable as equivalent value assets. The attachment order complied with Section 5(1) conditions, considering appellant's involvement in money laundering and potential risk of property alienation. Consequently, the appellate tribunal rejected appellant's challenges to the provisional attachment, affirming ED's actions as legally sustainable.
AT held that provisional attachment of four immovable properties under PMLA was valid. Despite three properties being acquired prior to the scheduled offence and one property acquired post-offence period, ED demonstrated sufficient grounds for attachment. The tribunal found appellant received Rs. 20 lakhs from proceeds of crime, rendering properties attachable as equivalent value assets. The attachment order complied with Section 5(1) conditions, considering appellant's involvement in money laundering and potential risk of property alienation. Consequently, the appellate tribunal rejected appellant's challenges to the provisional attachment, affirming ED's actions as legally sustainable.
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