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 upheld the provisional attachment order. The Tribunal found that the appellant failed to satisfactorily disclose the source of funds used to acquire the disputed property, including unexplained receipts aggregating Rs. 12 crore routed through intermediary entities and paid to a vendor's employee, and that documentary proof for asserted loans was not produced. The AT held that record-level statements sufficiently establish proceeds of crime and that Section 8(1) requires satisfaction on notice regarding source. The Tribunal endorsed attachment of property of equivalent value where original proceeds are unavailable and rejected mala fides/political vendetta allegations for lack of proof. The appeal therefore fails on all grounds.
AT dismissed the appeal and upheld the provisional attachment order. The Tribunal found that the appellant failed to satisfactorily disclose the source of funds used to acquire the disputed property, including unexplained receipts aggregating Rs. 12 crore routed through intermediary entities and paid to a vendor's employee, and that documentary proof for asserted loans was not produced. The AT held that record-level statements sufficiently establish proceeds of crime and that Section 8(1) requires satisfaction on notice regarding source. The Tribunal endorsed attachment of property of equivalent value where original proceeds are unavailable and rejected mala fides/political vendetta allegations for lack of proof. The appeal therefore fails on all grounds.
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