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 appeal challenging property attachment under money laundering proceedings involving large-scale misappropriation of scholarship funds. The tribunal rejected appellant's contention that no prosecution complaint was filed within 365 days, holding that attachment proceedings protect property until investigation conclusion and trial completion. The tribunal found sufficient evidence linking appellant to money laundering offenses, noting appellant's admission regarding fund sources from the consultancy company operating the educational institute. The tribunal emphasized that properties can be attached from any person possessing proceeds of crime, regardless of whether they are accused in the predicate offense. The tribunal concluded sufficient incriminating material existed against appellants for receiving proceeds of crime, dismissing all grounds of appeal.
The AT dismissed the appeal challenging property attachment under money laundering proceedings involving large-scale misappropriation of scholarship funds. The tribunal rejected appellant's contention that no prosecution complaint was filed within 365 days, holding that attachment proceedings protect property until investigation conclusion and trial completion. The tribunal found sufficient evidence linking appellant to money laundering offenses, noting appellant's admission regarding fund sources from the consultancy company operating the educational institute. The tribunal emphasized that properties can be attached from any person possessing proceeds of crime, regardless of whether they are accused in the predicate offense. The tribunal concluded sufficient incriminating material existed against appellants for receiving proceeds of crime, dismissing all grounds of appeal.
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