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 of properties held by the appellant and family as "equivalent value" of proceeds of crime under Sections 5 and 2(1)(u) PMLA, and dismissed the appeal. It found overwhelming evidence that the appellant fraudulently obtained foreign exchange by submitting forged documents to banks and remitted it abroad under the guise of software imports that never occurred. Statements of the appellant and collaborators of limited means corroborated a structured modus operandi, including creation of foreign entities to receive funds. Relying on the settled interpretation of "proceeds of crime" and "value thereof," AT rejected the contention that pre-crime acquisitions could not be attached.
AT upheld the provisional attachment of properties held by the appellant and family as "equivalent value" of proceeds of crime under Sections 5 and 2(1)(u) PMLA, and dismissed the appeal. It found overwhelming evidence that the appellant fraudulently obtained foreign exchange by submitting forged documents to banks and remitted it abroad under the guise of software imports that never occurred. Statements of the appellant and collaborators of limited means corroborated a structured modus operandi, including creation of foreign entities to receive funds. Relying on the settled interpretation of "proceeds of crime" and "value thereof," AT rejected the contention that pre-crime acquisitions could not be attached.
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