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 upheld the provisional attachment order under the PMLA against the appellants, rejecting their contentions that they were not named accused or connected to predicate offences. It was held that attachment can be made irrespective of FIR status, and the relevant date for proceeds calculation is when the property is projected as untainted, not the offence date. The appellants failed to prove legitimate sources for the attached properties. The ED's directions for police possession and account freezing beyond 30 days complied with statutory provisions and rules. No violation of procedural rules or requirements under Sections 8(2) and 8(3) of the PMLA was found. Consequently, the appeal was dismissed in favor of the ED.
The AT upheld the provisional attachment order under the PMLA against the appellants, rejecting their contentions that they were not named accused or connected to predicate offences. It was held that attachment can be made irrespective of FIR status, and the relevant date for proceeds calculation is when the property is projected as untainted, not the offence date. The appellants failed to prove legitimate sources for the attached properties. The ED's directions for police possession and account freezing beyond 30 days complied with statutory provisions and rules. No violation of procedural rules or requirements under Sections 8(2) and 8(3) of the PMLA was found. Consequently, the appeal was dismissed in favor of the ED.
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