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 appellant's application and upheld the provisional attachment of the immovable property under PMLA, holding that the respondent Directorate possessed sufficient material and reasons to believe under s.5(1) when issuing the Provisional Attachment Order. The Tribunal found the Directorate's case-though relying substantially on recorded statements-corroborated by documentary material showing diversion of export-linked bank loans for personal use, including acquisition of the attached property, and noted the Adjudicating Authority afforded the appellant opportunity to defend. The appellant's motion to reduce occupation and user charges was rejected for lack of evidentiary support and because the earlier stay did not mandate market-rent fixation; the application is dismissed.
The AT dismissed the appellant's application and upheld the provisional attachment of the immovable property under PMLA, holding that the respondent Directorate possessed sufficient material and reasons to believe under s.5(1) when issuing the Provisional Attachment Order. The Tribunal found the Directorate's case-though relying substantially on recorded statements-corroborated by documentary material showing diversion of export-linked bank loans for personal use, including acquisition of the attached property, and noted the Adjudicating Authority afforded the appellant opportunity to defend. The appellant's motion to reduce occupation and user charges was rejected for lack of evidentiary support and because the earlier stay did not mandate market-rent fixation; the application is dismissed.
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