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 upheld provisional attachment and dismissed the appeal, finding that appellant A's transfers to close relatives and cash investments could not be explained as legitimate savings and were largely derived from proceeds of crime connected to misappropriation of government funds. The Tribunal accepted respondents' computation that investments in healthcare infrastructure and capital subscriptions to M/s Pulse Sanjeevani Healthcare Pvt. Ltd. were financed predominantly by illicit funds, with bank loans insufficient to account for the outlays. Appellant P's unexplained cash deposits (≈Rs.73.81 lakhs), high-premium insurance payments and routing of cash through relatives (including B and C) evidenced money-laundering; seizure of cash corroborated involvement. No error found in the impugned order.
AT upheld provisional attachment and dismissed the appeal, finding that appellant A's transfers to close relatives and cash investments could not be explained as legitimate savings and were largely derived from proceeds of crime connected to misappropriation of government funds. The Tribunal accepted respondents' computation that investments in healthcare infrastructure and capital subscriptions to M/s Pulse Sanjeevani Healthcare Pvt. Ltd. were financed predominantly by illicit funds, with bank loans insufficient to account for the outlays. Appellant P's unexplained cash deposits (≈Rs.73.81 lakhs), high-premium insurance payments and routing of cash through relatives (including B and C) evidenced money-laundering; seizure of cash corroborated involvement. No error found in the impugned order.
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