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 all appeals, upholding attachment orders as the appellants were held to be in possession of proceeds of crime. The tribunal treated appellants' admissions and Section 50(2) witness statements as probative evidence of a fraudulent scheme siphoning bank funds, establishing that portions of the contested properties represented proceeds of crime. Claims that properties were acquired bona fide by registered sale deed failed for lack of disclosed lawful source of consideration. Allegations of procedural non-application of mind and non-involvement in the predicate offence were rejected as contrary to appellants' own admissions and the record. Consequently, the attachments stand and the appeals are dismissed.
The AT dismissed all appeals, upholding attachment orders as the appellants were held to be in possession of proceeds of crime. The tribunal treated appellants' admissions and Section 50(2) witness statements as probative evidence of a fraudulent scheme siphoning bank funds, establishing that portions of the contested properties represented proceeds of crime. Claims that properties were acquired bona fide by registered sale deed failed for lack of disclosed lawful source of consideration. Allegations of procedural non-application of mind and non-involvement in the predicate offence were rejected as contrary to appellants' own admissions and the record. Consequently, the attachments stand and the appeals are dismissed.
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