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 affirmed the provisional attachment order in a money laundering case involving fraudulent investment schemes. The tribunal rejected appellant's challenges, finding: (1) predicate offenses were substantiated through multiple FIRs and prosecution complaints, (2) section 420 IPC was a scheduled offense since 2009, and (3) substantial evidence existed showing over 200 crores fraudulently collected from public through deceptive housing and investment plans. The court emphasized that burden of proof lies with appellant to disclose property acquisition sources, and provisional attachment was justified under statutory provisions to prevent potential property concealment or transfer. Appeal was consequently dismissed, upholding the original attachment order.
AT affirmed the provisional attachment order in a money laundering case involving fraudulent investment schemes. The tribunal rejected appellant's challenges, finding: (1) predicate offenses were substantiated through multiple FIRs and prosecution complaints, (2) section 420 IPC was a scheduled offense since 2009, and (3) substantial evidence existed showing over 200 crores fraudulently collected from public through deceptive housing and investment plans. The court emphasized that burden of proof lies with appellant to disclose property acquisition sources, and provisional attachment was justified under statutory provisions to prevent potential property concealment or transfer. Appeal was consequently dismissed, upholding the original attachment order.
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