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, upholding the Provisional Attachment Order (PAO) dated 31.03.2016 and confirming attachment of the impugned properties. The Tribunal rejected the appellants' contention that the PMLA could not be applied retrospectively, noting the account was declared NPA and frozen on 31.03.2005, the PMLA came into force on 01.07.2005, and the relevant offences were included as Scheduled Offences prior to issuance of the PAO. The AT found sufficient material that the appellants participated in transactions to conceal proceeds and effect undervalued sales to evade attachment, thereby validating invocation of PMLA provisions and dismissing the appeal.
The AT dismissed the appeal, upholding the Provisional Attachment Order (PAO) dated 31.03.2016 and confirming attachment of the impugned properties. The Tribunal rejected the appellants' contention that the PMLA could not be applied retrospectively, noting the account was declared NPA and frozen on 31.03.2005, the PMLA came into force on 01.07.2005, and the relevant offences were included as Scheduled Offences prior to issuance of the PAO. The AT found sufficient material that the appellants participated in transactions to conceal proceeds and effect undervalued sales to evade attachment, thereby validating invocation of PMLA provisions and dismissing the appeal.
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