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, upholding provisional attachment orders and refusing interference. The Tribunal found a prima facie case of offence under Section 3 of the Act of 2002 and noted pending criminal proceedings against the appellants, precluding a finding of innocence; the 180-day termination calculation and exclusions were addressed against the appellants. The appellants failed to satisfactorily establish lawful source of attached assets: sale deeds were unregistered or unsupported, ancestral title and consideration documentation were inadequate, and claimed timber business records (firm registration, ledger accounts, invoices) were unreliable or handwritten and inconsistent with statements under Section 50(2)/(3). Relief from attachment was therefore denied and the appeals dismissed.
The AT dismissed the appeal, upholding provisional attachment orders and refusing interference. The Tribunal found a prima facie case of offence under Section 3 of the Act of 2002 and noted pending criminal proceedings against the appellants, precluding a finding of innocence; the 180-day termination calculation and exclusions were addressed against the appellants. The appellants failed to satisfactorily establish lawful source of attached assets: sale deeds were unregistered or unsupported, ancestral title and consideration documentation were inadequate, and claimed timber business records (firm registration, ledger accounts, invoices) were unreliable or handwritten and inconsistent with statements under Section 50(2)/(3). Relief from attachment was therefore denied and the appeals dismissed.
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