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 attachment of property under money laundering proceedings against the appellant, a bank branch manager accused of sanctioning unauthorized loans based on fabricated documents. The Tribunal reaffirmed that property acquired prior to the commission of the scheduled offence is not subject to attachment, but where proceeds of crime are not found with the accused due to their disappearance, property of equivalent value may be attached. The decision relied on established precedent confirming that attachment aims to prevent dissipation of criminal proceeds and enforce recovery even if the direct proceeds are unavailable. Given that the proceeds had vanished and were not in the appellant's possession, attachment of property of equivalent value was upheld. The impugned order was found legally sound, and no interference was warranted. The appeal was therefore dismissed.
The AT dismissed the appeal challenging the attachment of property under money laundering proceedings against the appellant, a bank branch manager accused of sanctioning unauthorized loans based on fabricated documents. The Tribunal reaffirmed that property acquired prior to the commission of the scheduled offence is not subject to attachment, but where proceeds of crime are not found with the accused due to their disappearance, property of equivalent value may be attached. The decision relied on established precedent confirming that attachment aims to prevent dissipation of criminal proceeds and enforce recovery even if the direct proceeds are unavailable. Given that the proceeds had vanished and were not in the appellant's possession, attachment of property of equivalent value was upheld. The impugned order was found legally sound, and no interference was warranted. The appeal was therefore dismissed.
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