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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Provisional attachment under the PMLA was sustained where investigators established a prima facie nexus between alleged proceeds of crime and conversion of demonetized currency into bullion and sale of jewellery, attracting the definition of proceeds of crime and prompting action under the Act; consequence: confirmation of attachment. The Tribunal affirmed that an undivided share in immovable property may be attached and physical divisibility or eviction is not required at the attachment stage; consequence: 50% attachment upheld. The claimant bears the burden to prove an attached portion is untainted and mere EMI payments or financial contribution without title do not establish ownership; consequence: impleadment and appeals dismissed.
Provisional attachment under the PMLA was sustained where investigators established a prima facie nexus between alleged proceeds of crime and conversion of demonetized currency into bullion and sale of jewellery, attracting the definition of proceeds of crime and prompting action under the Act; consequence: confirmation of attachment. The Tribunal affirmed that an undivided share in immovable property may be attached and physical divisibility or eviction is not required at the attachment stage; consequence: 50% attachment upheld. The claimant bears the burden to prove an attached portion is untainted and mere EMI payments or financial contribution without title do not establish ownership; consequence: impleadment and appeals dismissed.
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