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 Adjudicating Authority's order permitting retention of Rs. 65 lakhs seized from the appellant pending trial under the PMLA. The appellant failed to produce bank statements or credible documentation to substantiate the lawful source of the cash, including alleged savings of the appellant's wife. The appellant's own statement under Section 50 of the PMLA corroborated involvement in illegal arms licensing, a predicate offence under the Arms Act and Prevention of Corruption Act applicable post the abrogation of Jammu and Kashmir's special status. The appellant's failure to justify the seized amount and admissions of illegal activity justified continued seizure. The appeal was dismissed as the impugned order was found legally sound and not liable to interference.
The AT upheld the Adjudicating Authority's order permitting retention of Rs. 65 lakhs seized from the appellant pending trial under the PMLA. The appellant failed to produce bank statements or credible documentation to substantiate the lawful source of the cash, including alleged savings of the appellant's wife. The appellant's own statement under Section 50 of the PMLA corroborated involvement in illegal arms licensing, a predicate offence under the Arms Act and Prevention of Corruption Act applicable post the abrogation of Jammu and Kashmir's special status. The appellant's failure to justify the seized amount and admissions of illegal activity justified continued seizure. The appeal was dismissed as the impugned order was found legally sound and not liable to interference.
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