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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Attachment of immovable property acquired before a scheduled offence may be treated as proceeds of crime or as property of equivalent value where actual proceeds are untraceable; the article explains that the definition of proceeds of crime includes direct proceeds and equivalent value property, and that prior acquisition does not preclude attachment when a connection or equivalence is shown. It emphasises the statutory onus on persons claiming interest to prove legitimate source (absence of loan documentation and admissions defeated the claim). It further states that exclusion of the Covid 19 period applies in computing the 180 day limit for confirmation, rendering the confirmation timely.
Attachment of immovable property acquired before a scheduled offence may be treated as proceeds of crime or as property of equivalent value where actual proceeds are untraceable; the article explains that the definition of proceeds of crime includes direct proceeds and equivalent value property, and that prior acquisition does not preclude attachment when a connection or equivalence is shown. It emphasises the statutory onus on persons claiming interest to prove legitimate source (absence of loan documentation and admissions defeated the claim). It further states that exclusion of the Covid 19 period applies in computing the 180 day limit for confirmation, rendering the confirmation timely.
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