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 and upheld the provisional attachment of 68% of the immovable property, concluding that the PMLA amendments effective 15.02.2013 applied and that enforcement action was lawfully initiated post-amendment (ECIR registered 27.10.2015; PAO issued 26.07.2018, confirmed 11.01.2019). The Tribunal found sufficient evidence that the appellant knowingly handled proceeds of crime-cash deposits, inconsistent explanations about sales and transport, and reliance on false documentation-yielding identified laundered proceeds of Rs. 11,41,800.00. Reliance on contrary interim orders and family-settlement title were rejected; proceedings under the PMLA and attachment were sustained as legally valid and proportionate.
The AT dismissed the appeal and upheld the provisional attachment of 68% of the immovable property, concluding that the PMLA amendments effective 15.02.2013 applied and that enforcement action was lawfully initiated post-amendment (ECIR registered 27.10.2015; PAO issued 26.07.2018, confirmed 11.01.2019). The Tribunal found sufficient evidence that the appellant knowingly handled proceeds of crime-cash deposits, inconsistent explanations about sales and transport, and reliance on false documentation-yielding identified laundered proceeds of Rs. 11,41,800.00. Reliance on contrary interim orders and family-settlement title were rejected; proceedings under the PMLA and attachment were sustained as legally valid and proportionate.
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