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 appeal and affirmed the Adjudicating Authority's confirmation of the Provisional Attachment Order under Section 24(4)(b) of the Benami Transactions (Prohibition) Act, 1988. The Tribunal held the PAO validly issued with Approving Authority's concurrence and not subject to the stricter apprehension-of-alienation requirement of Section 24(3). The appellant failed to satisfactorily disclose the source of Rs. 2 crore; the transaction was found to satisfy Section 2(9)(D) as a benami transaction and the appellant was treated as benamidar. The AT ruled that taxation under Sections 68/69A of the IT Act does not preclude proceedings under the Benami Act. Appeal dismissed.
AT dismissed the appeal and affirmed the Adjudicating Authority's confirmation of the Provisional Attachment Order under Section 24(4)(b) of the Benami Transactions (Prohibition) Act, 1988. The Tribunal held the PAO validly issued with Approving Authority's concurrence and not subject to the stricter apprehension-of-alienation requirement of Section 24(3). The appellant failed to satisfactorily disclose the source of Rs. 2 crore; the transaction was found to satisfy Section 2(9)(D) as a benami transaction and the appellant was treated as benamidar. The AT ruled that taxation under Sections 68/69A of the IT Act does not preclude proceedings under the Benami Act. Appeal dismissed.
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