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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The note addresses provisional attachment in disproportionate assets proceedings, emphasising that the appellant bore the burden to prove lawful sources of funds under Section 24 of the relevant Act and failed to do so, so the attachment was sustained. The tribunal accepted valuation used for asset assessment and held that even if some property values were conservatively assessed, higher valuations would only increase alleged disproportion. Repeated unexplained cash deposits across family bank accounts were treated as unexplained proceeds relevant to the attachment. Absent credible documentary proof of income or sources, the impugned provisional attachment order was not interfered with and the appeals were dismissed.
The note addresses provisional attachment in disproportionate assets proceedings, emphasising that the appellant bore the burden to prove lawful sources of funds under Section 24 of the relevant Act and failed to do so, so the attachment was sustained. The tribunal accepted valuation used for asset assessment and held that even if some property values were conservatively assessed, higher valuations would only increase alleged disproportion. Repeated unexplained cash deposits across family bank accounts were treated as unexplained proceeds relevant to the attachment. Absent credible documentary proof of income or sources, the impugned provisional attachment order was not interfered with and the appeals were dismissed.
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