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 of properties was sustained because the respondent traced a money trail and layering of alleged proceeds of crime into properties, and the appellant failed to discharge the statutory burden to disclose source of funds under Section 24. The tribunal accepted that transfers from relatives, described as loans, lacked provenance and were routed through multiple bank accounts to mask cash derived from the offence; repayment of earlier loans and purchase payments were therefore treated as involving proceeds of crime. On that basis the Adjudicating Authority's confirmation of the Provisional Attachment Order was upheld and the appeal dismissed.
Provisional attachment of properties was sustained because the respondent traced a money trail and layering of alleged proceeds of crime into properties, and the appellant failed to discharge the statutory burden to disclose source of funds under Section 24. The tribunal accepted that transfers from relatives, described as loans, lacked provenance and were routed through multiple bank accounts to mask cash derived from the offence; repayment of earlier loans and purchase payments were therefore treated as involving proceeds of crime. On that basis the Adjudicating Authority's confirmation of the Provisional Attachment Order was upheld and the appeal dismissed.
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