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 attachment of four properties as "proceeds of crime" under PMLA. It declined to re-evaluate investigative evidence because the appellant and co-accused face trial for the predicate offence and ED lacks power to re-investigate the scheduled offence. Two properties purchased in 2011 were held to be directly acquired from criminal proceeds; two earlier acquisitions were held attachable under the second limb of "proceeds of crime" as equivalent value where proceeds were siphoned off and unavailable. The AT applied binding higher-court precedent interpreting the statutory definition and concluded attachment of equivalent value was lawful, thereby rejecting the appellant's grounds.
The AT dismissed the appeal, upholding attachment of four properties as "proceeds of crime" under PMLA. It declined to re-evaluate investigative evidence because the appellant and co-accused face trial for the predicate offence and ED lacks power to re-investigate the scheduled offence. Two properties purchased in 2011 were held to be directly acquired from criminal proceeds; two earlier acquisitions were held attachable under the second limb of "proceeds of crime" as equivalent value where proceeds were siphoned off and unavailable. The AT applied binding higher-court precedent interpreting the statutory definition and concluded attachment of equivalent value was lawful, thereby rejecting the appellant's grounds.
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