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 upheld the provisional attachment order under the PMLA, holding that appellants A1-A3 were prima facie involved in the scheduled (predicate) offence and consequent money laundering. Investigations pursuant to FIRs and ECIR established that they extorted money using muscle power, procured land documents, manipulated revenue records, and sold properties, thereby generating "proceeds of crime" and projecting them as untainted. The quantification of proceeds of crime was based on these findings. AT noted that appellants failed to disclose any legitimate source of funds or produce evidence for the purchase of the attached properties. Distinguishing reliance on the SC order cited, AT found no ground to interfere with the impugned order. The appeals were dismissed.
AT upheld the provisional attachment order under the PMLA, holding that appellants A1-A3 were prima facie involved in the scheduled (predicate) offence and consequent money laundering. Investigations pursuant to FIRs and ECIR established that they extorted money using muscle power, procured land documents, manipulated revenue records, and sold properties, thereby generating "proceeds of crime" and projecting them as untainted. The quantification of proceeds of crime was based on these findings. AT noted that appellants failed to disclose any legitimate source of funds or produce evidence for the purchase of the attached properties. Distinguishing reliance on the SC order cited, AT found no ground to interfere with the impugned order. The appeals were dismissed.
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