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 against the appellant's properties, finding that the appellant failed to discharge the statutory burden of proving the legitimate source of funds used for their acquisition. The bank statements showed deposits with narrations "TRF" and "Cash" preceding part-payments of consideration, but the nature and source of these deposits remained unexplained. AT held that "reasons to believe" under S. 5(1) PMLA were properly recorded, as the Joint Director had elaborately set out the predicate (scheduled) offence, the alleged leaking of examination papers for consideration, and the related financial transactions. Finding no legal infirmity, AT dismissed the appeal and confirmed the attachment.
AT upheld the Provisional Attachment Order under the PMLA against the appellant's properties, finding that the appellant failed to discharge the statutory burden of proving the legitimate source of funds used for their acquisition. The bank statements showed deposits with narrations "TRF" and "Cash" preceding part-payments of consideration, but the nature and source of these deposits remained unexplained. AT held that "reasons to believe" under S. 5(1) PMLA were properly recorded, as the Joint Director had elaborately set out the predicate (scheduled) offence, the alleged leaking of examination papers for consideration, and the related financial transactions. Finding no legal infirmity, AT dismissed the appeal and confirmed the attachment.
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