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 under the Act was upheld where funds raised by a bitcoin scheme were identified as proceeds of crime and laundered through layered banking transactions, asset purchases and shell entities; the Adjudicating Authority's characterisation of the impugned properties as tainted was supported by admissions and bank-trace analysis, and attachment was confirmed. Attachment was permissible despite the properties being held by persons not yet named as accused where material indicated possession of proceeds. Rapid, unexplained loan repayment was treated as indicative of layering. Death of the principal did not nullify attachment absent a recorded order of abatement; apprehension of alienation justified provisional attachment.
Provisional attachment under the Act was upheld where funds raised by a bitcoin scheme were identified as proceeds of crime and laundered through layered banking transactions, asset purchases and shell entities; the Adjudicating Authority's characterisation of the impugned properties as tainted was supported by admissions and bank-trace analysis, and attachment was confirmed. Attachment was permissible despite the properties being held by persons not yet named as accused where material indicated possession of proceeds. Rapid, unexplained loan repayment was treated as indicative of layering. Death of the principal did not nullify attachment absent a recorded order of abatement; apprehension of alienation justified provisional attachment.
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