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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AT dismissed the appeals and upheld retention of the appellant's frozen bank accounts pending trial. The Tribunal found sufficient prima facie evidence linking the appellant and associated corporate entities to an alleged Ponzi/MLM money-circulation scheme, including benami firm usage, routing of proceeds through related companies and personal accounts, recovery of incriminating material on search, and receipt of large "commissions." The appellant failed to discharge the statutory obligation under s.8(1) of the Act to explain the source of funds; statements under ss.50(2)-50(3) were treated as corroborative. On these findings, AT concluded continued attachment of funds was justified and dismissed the appeals for lack of merit.
AT dismissed the appeals and upheld retention of the appellant's frozen bank accounts pending trial. The Tribunal found sufficient prima facie evidence linking the appellant and associated corporate entities to an alleged Ponzi/MLM money-circulation scheme, including benami firm usage, routing of proceeds through related companies and personal accounts, recovery of incriminating material on search, and receipt of large "commissions." The appellant failed to discharge the statutory obligation under s.8(1) of the Act to explain the source of funds; statements under ss.50(2)-50(3) were treated as corroborative. On these findings, AT concluded continued attachment of funds was justified and dismissed the appeals for lack of merit.
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