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 Prevention of Money Laundering Act against the appellant NBFC and associated entities operating instant micro-loan mobile applications. AT found that the business model-charging 30-40% processing fees on very short-term loans, resulting in effective interest rates exceeding 1500% per annum, coupled with abusive recovery practices and misuse of personal data-constituted unfair practices and violated RBI's regulatory framework and fair practice requirements. AT rejected the appellant's contention that core NBFC functions were lawfully outsourced, holding that key management functions had impermissibly been delegated to service providers. Considering the exploitative nature of the operations and reported borrower suicides, AT concluded that the revenue constituted proceeds of crime and dismissed the appeal, confirming the attachment.
AT upheld the provisional attachment order under the Prevention of Money Laundering Act against the appellant NBFC and associated entities operating instant micro-loan mobile applications. AT found that the business model-charging 30-40% processing fees on very short-term loans, resulting in effective interest rates exceeding 1500% per annum, coupled with abusive recovery practices and misuse of personal data-constituted unfair practices and violated RBI's regulatory framework and fair practice requirements. AT rejected the appellant's contention that core NBFC functions were lawfully outsourced, holding that key management functions had impermissibly been delegated to service providers. Considering the exploitative nature of the operations and reported borrower suicides, AT concluded that the revenue constituted proceeds of crime and dismissed the appeal, confirming the attachment.
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