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 examined the challenge to the Impugned Order on the ground that it was passed beyond 180 days from the Provisional Attachment Order. Relying on prior AT precedent and the exclusion of Covid-19 period as per the Apex Court's suo motu directions, AT held that the limitation stood validly extended and the Impugned Order was not time-barred. AT further held that the appellant's statement under Section 50(2) of the 2002 Act is admissible and, on scrutiny, showed that certain bank credits and investments were unexplained as legitimate earnings. Consequently, provisional attachment of the identified amounts as proceeds of crime was upheld, to remain subject to the final outcome of the pending trial, and the appeal was disposed of.
AT examined the challenge to the Impugned Order on the ground that it was passed beyond 180 days from the Provisional Attachment Order. Relying on prior AT precedent and the exclusion of Covid-19 period as per the Apex Court's suo motu directions, AT held that the limitation stood validly extended and the Impugned Order was not time-barred. AT further held that the appellant's statement under Section 50(2) of the 2002 Act is admissible and, on scrutiny, showed that certain bank credits and investments were unexplained as legitimate earnings. Consequently, provisional attachment of the identified amounts as proceeds of crime was upheld, to remain subject to the final outcome of the pending trial, and the appeal was disposed of.
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