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 orders. The Tribunal found the appellants failed to disclose the source of funds for property acquisitions, discredited their witness-statements and uncorroborated explanations, and determined agricultural receipts and firm income could not account for the purchases. The AT accepted the enforcement analysis of declared income and banking transactions, including use of third-party accounts to funnel cash, and concluded proceeds of crime were either not traceable or vanished; accordingly, properties of equivalent value, including some acquired prior to the predicate acts, were lawfully provisionally attached as "proceeds of crime." The challenge to linkage with the alleged predicate offence and related notifications was rejected. Appeal dismissed.
The AT dismissed the appeal and upheld the provisional attachment orders. The Tribunal found the appellants failed to disclose the source of funds for property acquisitions, discredited their witness-statements and uncorroborated explanations, and determined agricultural receipts and firm income could not account for the purchases. The AT accepted the enforcement analysis of declared income and banking transactions, including use of third-party accounts to funnel cash, and concluded proceeds of crime were either not traceable or vanished; accordingly, properties of equivalent value, including some acquired prior to the predicate acts, were lawfully provisionally attached as "proceeds of crime." The challenge to linkage with the alleged predicate offence and related notifications was rejected. Appeal dismissed.
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