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 refused the appellant's challenge to provisional attachments effected by the ED, holding that the aggregate alleged proceeds of crime (POC) attributable to the accused persons substantially exceed the quantum of assets attached to date. The Tribunal determined that the relative increase in attached properties, even if limited and characterized as direct or indirect POC, does not warrant release of the appellant's assets because the risk of dissipation and the continuing nexus to the alleged criminal receipts remains. On that basis the appellant's application for interim release of the impugned properties was dismissed and no relief was granted.
The AT refused the appellant's challenge to provisional attachments effected by the ED, holding that the aggregate alleged proceeds of crime (POC) attributable to the accused persons substantially exceed the quantum of assets attached to date. The Tribunal determined that the relative increase in attached properties, even if limited and characterized as direct or indirect POC, does not warrant release of the appellant's assets because the risk of dissipation and the continuing nexus to the alleged criminal receipts remains. On that basis the appellant's application for interim release of the impugned properties was dismissed and no relief was granted.
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