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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The AT adjudicated a complex financial dispute involving money laundering and secured creditor rights. The tribunal held that while PMLA is a special act with precedence, the secured creditor (AARC) can stake claim before the PMLA Special Judge for property auction. The creditor must submit an undertaking to deposit any excess auction proceeds with ED via fixed deposit receipts. The court mandated inviting objections from interested parties and directed that final disposition of funds shall occur post-trial conclusion, effectively balancing investigative interests with creditor rights under SARFAESI and PMLA provisions.
The AT adjudicated a complex financial dispute involving money laundering and secured creditor rights. The tribunal held that while PMLA is a special act with precedence, the secured creditor (AARC) can stake claim before the PMLA Special Judge for property auction. The creditor must submit an undertaking to deposit any excess auction proceeds with ED via fixed deposit receipts. The court mandated inviting objections from interested parties and directed that final disposition of funds shall occur post-trial conclusion, effectively balancing investigative interests with creditor rights under SARFAESI and PMLA provisions.
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