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 text addresses provisional attachment of property alleged to be purchased using proceeds of crime through a bank loan, focusing on beneficial ownership and benami transactions. It explains that accommodated LC discounting transactions were used to generate illicit funds, that recorded witness statements implicated the arranger and beneficiaries, and that loan disbursement and EMI repayments were effected by unexplained cash deposits traced to the arranger. On that factual matrix the adjudicating authority confirmed attachment and the appeal was dismissed.
The text addresses provisional attachment of property alleged to be purchased using proceeds of crime through a bank loan, focusing on beneficial ownership and benami transactions. It explains that accommodated LC discounting transactions were used to generate illicit funds, that recorded witness statements implicated the arranger and beneficiaries, and that loan disbursement and EMI repayments were effected by unexplained cash deposits traced to the arranger. On that factual matrix the adjudicating authority confirmed attachment and the appeal was dismissed.
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