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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Proceeds of crime includes the value of tainted property and its equivalent, permitting provisional attachment even if the property holder is not accused; the tribunal applied the 'value of any such property' limb and treated bank deposits, confessional statements and corroborative seizures as sufficient material to form 'reason to believe', rejecting explanations of family transactions. The adjudicatory finding that unexplained income, expenditure and investments, together with seized cash and gold and transactional patterns, justified confirmation of provisional attachment was sustained and the appeal dismissed for lack of merit.
Proceeds of crime includes the value of tainted property and its equivalent, permitting provisional attachment even if the property holder is not accused; the tribunal applied the 'value of any such property' limb and treated bank deposits, confessional statements and corroborative seizures as sufficient material to form 'reason to believe', rejecting explanations of family transactions. The adjudicatory finding that unexplained income, expenditure and investments, together with seized cash and gold and transactional patterns, justified confirmation of provisional attachment was sustained and the appeal dismissed for lack of merit.
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