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 held that the provisional attachment order (PAO) under Section 5(1) of the PMLA was validly issued. The Deputy Director possessed and recorded in writing adequate reasons to believe, grounded in seized cash, FIRs, fund transfers, witness statements and account transaction records demonstrating transfers from entities controlled by the appellants and a prima facie contravention of statutory norms. The Tribunal found the satisfaction to be a subjective yet material-based belief of a reasonable officer, not mere ipsi dixit, and that the statutory procedure did not mandate pre-decision communication of the recorded reasons to the appellants. Given the availability of a post-attachment hearing before the Adjudicating Authority, the application was disposed of.
AT held that the provisional attachment order (PAO) under Section 5(1) of the PMLA was validly issued. The Deputy Director possessed and recorded in writing adequate reasons to believe, grounded in seized cash, FIRs, fund transfers, witness statements and account transaction records demonstrating transfers from entities controlled by the appellants and a prima facie contravention of statutory norms. The Tribunal found the satisfaction to be a subjective yet material-based belief of a reasonable officer, not mere ipsi dixit, and that the statutory procedure did not mandate pre-decision communication of the recorded reasons to the appellants. Given the availability of a post-attachment hearing before the Adjudicating Authority, the application was disposed of.
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