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 disposed of appeals regarding provisional attachment order under money laundering proceedings where appellant challenged quantification of proceeds of crime beyond specified offence period of May 2009 to August 2010. The tribunal declined to adjudicate on contentious issue of whether proceeds should be calculated based on excess production profits or environmental restoration costs, noting absence of judicial precedent or statutory provision. Appeals disposed of with liberty granted to appellant company to raise all material issues including period limitations and quantification methodology before Special Judge PMLA Court during trial proceedings where prosecution complaint under Sections 3 and 4 PMLA remains pending with charges yet to be framed.
AT disposed of appeals regarding provisional attachment order under money laundering proceedings where appellant challenged quantification of proceeds of crime beyond specified offence period of May 2009 to August 2010. The tribunal declined to adjudicate on contentious issue of whether proceeds should be calculated based on excess production profits or environmental restoration costs, noting absence of judicial precedent or statutory provision. Appeals disposed of with liberty granted to appellant company to raise all material issues including period limitations and quantification methodology before Special Judge PMLA Court during trial proceedings where prosecution complaint under Sections 3 and 4 PMLA remains pending with charges yet to be framed.
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