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 partially set aside the Provisional Attachment Order related to money laundering allegations involving fraudulent loan obtainment. The tribunal recognized the secured creditors' rights, allowing auction proceedings for mortgaged properties while directing the excess amounts be deposited as Fixed Deposit Receipts with ED. The decision preserves the auction sale in favor of the purchaser and permits SBI to proceed with e-auction under Section 8(7) of PMLA, 2002, subject to judicial oversight by the Special Judge. The excess realized amounts shall be maintained for potential claims by unsecured creditors, with final disposition contingent upon trial conclusion.
The AT partially set aside the Provisional Attachment Order related to money laundering allegations involving fraudulent loan obtainment. The tribunal recognized the secured creditors' rights, allowing auction proceedings for mortgaged properties while directing the excess amounts be deposited as Fixed Deposit Receipts with ED. The decision preserves the auction sale in favor of the purchaser and permits SBI to proceed with e-auction under Section 8(7) of PMLA, 2002, subject to judicial oversight by the Special Judge. The excess realized amounts shall be maintained for potential claims by unsecured creditors, with final disposition contingent upon trial conclusion.
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