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 freezing of 55 bank accounts and seizure of digital devices and documents linked to the appellant, who was found complicit in issuing fake cash receipts and receiving proceeds of crime amounting to Rs. 126 Crores. The appellant manipulated company records and benefited from bounced cheques deposited into personal and associates' accounts. The Tribunal found no illegality in the impugned order, noting the appellant's involvement was established through witness statements and investigation, despite the initial FIR naming only the company's MD. The appellant's claim of being a Commission Agent lacked documentary support and was dismissed as an attempt to conceal proceeds of crime. The Tribunal allowed limited operation of the frozen accounts, restricting access to amounts not exceeding the proceeds involved. The appeals were dismissed with no interference, affirming the measures taken to prevent layering of criminal proceeds and protect investor interests.
The AT upheld the freezing of 55 bank accounts and seizure of digital devices and documents linked to the appellant, who was found complicit in issuing fake cash receipts and receiving proceeds of crime amounting to Rs. 126 Crores. The appellant manipulated company records and benefited from bounced cheques deposited into personal and associates' accounts. The Tribunal found no illegality in the impugned order, noting the appellant's involvement was established through witness statements and investigation, despite the initial FIR naming only the company's MD. The appellant's claim of being a Commission Agent lacked documentary support and was dismissed as an attempt to conceal proceeds of crime. The Tribunal allowed limited operation of the frozen accounts, restricting access to amounts not exceeding the proceeds involved. The appeals were dismissed with no interference, affirming the measures taken to prevent layering of criminal proceeds and protect investor interests.
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