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 and upheld the provisional attachment under PMLA, holding the Special Court (PMLA) order non-final but not vitiated on the present record. The Tribunal found diversion of sanctioned loan proceeds constituted money laundering-inter alia a transfer of Rs.115 crore to a third party to prop up DHFL shares-and sustained attachment equivalent to the unpaid loan. The AT rejected the contention that initiation of NCLT/IBC proceedings and appointment of an IRP over a respondent's assets ousted PMLA action, reiterating that insolvency moratorium does not preclude criminal/asset-protection measures under the ECIR. All challenges to the attachment were found devoid of substance; appeal dismissed.
The AT dismissed the appeal and upheld the provisional attachment under PMLA, holding the Special Court (PMLA) order non-final but not vitiated on the present record. The Tribunal found diversion of sanctioned loan proceeds constituted money laundering-inter alia a transfer of Rs.115 crore to a third party to prop up DHFL shares-and sustained attachment equivalent to the unpaid loan. The AT rejected the contention that initiation of NCLT/IBC proceedings and appointment of an IRP over a respondent's assets ousted PMLA action, reiterating that insolvency moratorium does not preclude criminal/asset-protection measures under the ECIR. All challenges to the attachment were found devoid of substance; appeal dismissed.
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