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 dismissed the appellant's challenge to property attachment under PMLA, confirming the Adjudicating Authority's decision. The appellant paid Rs. 14,79,816 of Rs. 29,79,816 property consideration through installments during the predicate offence period, constituting proceeds of crime. The total allegation of Rs. 16,99,000 approximately equals the appellant's part payment, establishing nexus between property acquisition and criminal proceeds. The tribunal found no valid grounds for appeal and determined premature release inappropriate with pending scheduled offence trial. While dismissing the appeal as meritless, the AT directed ED to refrain from coercive possession or confiscation steps until criminal trial finalization, except under exceptional circumstances.
The AT dismissed the appellant's challenge to property attachment under PMLA, confirming the Adjudicating Authority's decision. The appellant paid Rs. 14,79,816 of Rs. 29,79,816 property consideration through installments during the predicate offence period, constituting proceeds of crime. The total allegation of Rs. 16,99,000 approximately equals the appellant's part payment, establishing nexus between property acquisition and criminal proceeds. The tribunal found no valid grounds for appeal and determined premature release inappropriate with pending scheduled offence trial. While dismissing the appeal as meritless, the AT directed ED to refrain from coercive possession or confiscation steps until criminal trial finalization, except under exceptional circumstances.
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