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 affirms dismissal of the appellant's challenge to a provisional attachment order under money-laundering law. The Tribunal, applying higher-court precedent and statutory definition of "proceeds of crime," held that where proceeds have been dissipated, property of equivalent value may be provisionally attached. The respondents quantified proceeds at Rs.6,13,74,440, from which the appellant was shown to have received Rs.40,00,000; as those funds were not available, a property valued at Rs.16,60,000 acquired during the scheduled offence period was provisionally attached. Finding no merit in the sole ground of appeal, the AT dismissed the appeal and sustained the provisional attachment.
The AT affirms dismissal of the appellant's challenge to a provisional attachment order under money-laundering law. The Tribunal, applying higher-court precedent and statutory definition of "proceeds of crime," held that where proceeds have been dissipated, property of equivalent value may be provisionally attached. The respondents quantified proceeds at Rs.6,13,74,440, from which the appellant was shown to have received Rs.40,00,000; as those funds were not available, a property valued at Rs.16,60,000 acquired during the scheduled offence period was provisionally attached. Finding no merit in the sole ground of appeal, the AT dismissed the appeal and sustained the provisional attachment.
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