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 a provisional attachment limited to proceeds quantified at Rs. 3,98,000. The Tribunal held that criminal proceedings under IPC and the PC Act remain subsisting and the appellant is not discharged; prima facie receipt of bribe money to that extent is established for provisional forfeiture. Allegations concerning acquisition of two shops at undervalue were not sustained in the supplementary charge-sheet, so attachment cannot extend on that basis; however, if bank balances suffice to satisfy Rs. 3,98,000 the attachment may be continued against those funds and residual provisional attachment (including Shop No.1001) may be maintained. The order is interim and subject to final trial outcome.
AT dismissed the appeal and upheld a provisional attachment limited to proceeds quantified at Rs. 3,98,000. The Tribunal held that criminal proceedings under IPC and the PC Act remain subsisting and the appellant is not discharged; prima facie receipt of bribe money to that extent is established for provisional forfeiture. Allegations concerning acquisition of two shops at undervalue were not sustained in the supplementary charge-sheet, so attachment cannot extend on that basis; however, if bank balances suffice to satisfy Rs. 3,98,000 the attachment may be continued against those funds and residual provisional attachment (including Shop No.1001) may be maintained. The order is interim and subject to final trial outcome.
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