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 the provisional attachment of property under the Prevention of Money Laundering Act. The appellant admitted receipt of Rs. 9.5 crores from the accused, characterized as proceeds of crime linked to the preparation of fake bills of entry and foreign remittances. Despite the appellant's claim that the amount was a bona fide loan, no loan documentation or evidence of repayment was produced. The Tribunal held that the admitted receipt of criminal proceeds justified attachment to secure the property pending trial. The appellant's role as director of the associated entity and the corroborative statements further supported the attachment. No grounds for interference with the impugned order were found, and the appeal was accordingly dismissed.
The AT dismissed the appeal challenging the provisional attachment of property under the Prevention of Money Laundering Act. The appellant admitted receipt of Rs. 9.5 crores from the accused, characterized as proceeds of crime linked to the preparation of fake bills of entry and foreign remittances. Despite the appellant's claim that the amount was a bona fide loan, no loan documentation or evidence of repayment was produced. The Tribunal held that the admitted receipt of criminal proceeds justified attachment to secure the property pending trial. The appellant's role as director of the associated entity and the corroborative statements further supported the attachment. No grounds for interference with the impugned order were found, and the appeal was accordingly dismissed.
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