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 upheld the provisional attachment order under PMLA, finding the appellant failed to disclose the source of funds for property acquisition valued at Rs. 24 lakhs. The tribunal determined the property was purchased through fraudulent means, with significant undervaluation and suspicious financial transactions. The appellant, despite being a legal professional, could not substantiate the legitimate origin of funds. The court rejected arguments about property valuation and confirmed the attachment, emphasizing the obligation to demonstrate transparent fund sources. Consequently, the appeal was dismissed, maintaining the original attachment order as proceeds of crime under section 8(1) of the PMLA.
AT upheld the provisional attachment order under PMLA, finding the appellant failed to disclose the source of funds for property acquisition valued at Rs. 24 lakhs. The tribunal determined the property was purchased through fraudulent means, with significant undervaluation and suspicious financial transactions. The appellant, despite being a legal professional, could not substantiate the legitimate origin of funds. The court rejected arguments about property valuation and confirmed the attachment, emphasizing the obligation to demonstrate transparent fund sources. Consequently, the appeal was dismissed, maintaining the original attachment order as proceeds of crime under section 8(1) of the PMLA.
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