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 Prevention of Money Laundering Act, 2002, confirming that attachment is permissible against any person in possession of proceeds of crime, not solely the accused. The appellant, though not named in the FIR or prosecution complaint, controlled companies receiving laundered proceeds linked to the predicate offence. The Tribunal rejected the appellant's challenge, emphasizing that the Act's provisions extend to third-party possession to prevent frustration of its objectives. Confiscation was deemed premature as the trial is incomplete. The attachment of property amounting to Rs. 11.35 crores, corresponding to laundered proceeds held by the appellant's controlled entities, was affirmed. No illegality was found in the attachment order, and the appeal was dismissed.
The AT upheld the provisional attachment order under the Prevention of Money Laundering Act, 2002, confirming that attachment is permissible against any person in possession of proceeds of crime, not solely the accused. The appellant, though not named in the FIR or prosecution complaint, controlled companies receiving laundered proceeds linked to the predicate offence. The Tribunal rejected the appellant's challenge, emphasizing that the Act's provisions extend to third-party possession to prevent frustration of its objectives. Confiscation was deemed premature as the trial is incomplete. The attachment of property amounting to Rs. 11.35 crores, corresponding to laundered proceeds held by the appellant's controlled entities, was affirmed. No illegality was found in the attachment order, and the appeal was dismissed.
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