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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Quashing of an FIR against one accused does not automatically invalidate parallel PMLA investigation, ECIR recording or provisional attachment where predicate offences remain disclosed and proceedings against other persons continue; the continuation of proceedings and attachment was therefore sustained. Transfers routed through a web of companies were held to be paper/shell transactions in the absence of loan documentation, balance sheet entries or supporting books, and contemporaneous material traced the money trail to disputed properties. Under the statutory allocation of burden (notice obligations and the onus under Section 24), appellants failed to disclose or prove lawful source of funds, justifying confirmation of provisional attachment.
Quashing of an FIR against one accused does not automatically invalidate parallel PMLA investigation, ECIR recording or provisional attachment where predicate offences remain disclosed and proceedings against other persons continue; the continuation of proceedings and attachment was therefore sustained. Transfers routed through a web of companies were held to be paper/shell transactions in the absence of loan documentation, balance sheet entries or supporting books, and contemporaneous material traced the money trail to disputed properties. Under the statutory allocation of burden (notice obligations and the onus under Section 24), appellants failed to disclose or prove lawful source of funds, justifying confirmation of provisional attachment.
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