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 PMLA was reviewed: the forensic audit report was treated as guidance only because of express disclaimers and incomplete records, not as conclusive proof; the agency's independent investigation and documentary transfers to certain companies supported a proceeds-of-crime finding. The relevant date for a scheduled offence is when the ECIR recorded an offence, not the original act date, and concealment or projection of tainted money can establish liability. Consequentially, attachment of the Goa land parcel and properties of five subsequently constituted LLPs was set aside, while bank account attachment to the extent of balances and share-related attachments remain unaffected.
Provisional attachment under PMLA was reviewed: the forensic audit report was treated as guidance only because of express disclaimers and incomplete records, not as conclusive proof; the agency's independent investigation and documentary transfers to certain companies supported a proceeds-of-crime finding. The relevant date for a scheduled offence is when the ECIR recorded an offence, not the original act date, and concealment or projection of tainted money can establish liability. Consequentially, attachment of the Goa land parcel and properties of five subsequently constituted LLPs was set aside, while bank account attachment to the extent of balances and share-related attachments remain unaffected.
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