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 HC refused the Income Tax Department's application to appropriate fixed deposit receipts seized from Respondents pending a PMLA investigation, holding the seized funds are prima facie proceeds of crime rather than taxable income. Applying statutory definitions and the dominant-purpose analysis, the court determined that PMLA's forfeiture and restoration objectives prevail over revenue recovery where the character of the funds is under criminal adjudication. Consequently, the IT Dept may not treat or appropriate the FDR amounts as income for tax recovery until conclusion of the PMLA trial and related criminal adjudication; the Department's application was dismissed and the petition rejected.
The HC refused the Income Tax Department's application to appropriate fixed deposit receipts seized from Respondents pending a PMLA investigation, holding the seized funds are prima facie proceeds of crime rather than taxable income. Applying statutory definitions and the dominant-purpose analysis, the court determined that PMLA's forfeiture and restoration objectives prevail over revenue recovery where the character of the funds is under criminal adjudication. Consequently, the IT Dept may not treat or appropriate the FDR amounts as income for tax recovery until conclusion of the PMLA trial and related criminal adjudication; the Department's application was dismissed and the petition rejected.
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