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 order under the PMLA, holding that the appellants failed to satisfactorily disclose the sources of funds credited to their bank accounts. Evidence demonstrated that substantial amounts received by the appellants and related entities were proceeds of crime linked to fraudulent export activities. The appellants could not substantiate the legitimacy of the funds, nor provide credible documentation such as loan agreements or valid explanations for the transfers. The tribunal noted the close familial and transactional connections between the appellants and accused persons involved in money laundering. Given the lack of credible disclosure and the established nexus to criminal proceeds, the impugned attachment order was upheld, with no grounds for interference in favor of the appellants.
The AT dismissed the appeal challenging the provisional attachment order under the PMLA, holding that the appellants failed to satisfactorily disclose the sources of funds credited to their bank accounts. Evidence demonstrated that substantial amounts received by the appellants and related entities were proceeds of crime linked to fraudulent export activities. The appellants could not substantiate the legitimacy of the funds, nor provide credible documentation such as loan agreements or valid explanations for the transfers. The tribunal noted the close familial and transactional connections between the appellants and accused persons involved in money laundering. Given the lack of credible disclosure and the established nexus to criminal proceeds, the impugned attachment order was upheld, with no grounds for interference in favor of the appellants.
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