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 PMLA was confirmed on the basis that cumulative material - statements under section 50(2) PMLA, searches, bank and property linkages and a disclosed modus operandi - established receipt and layering of proceeds of crime, with a statement under the Income Tax Act admitted only as corroboration. Objection that Regulation 3 language requirements were breached was rejected on factual findings that English translations and gists were furnished and witnesses understood Bengali. The Tribunal construed provisional attachment as permissible during investigation or related proceedings and upheld attachment of assets in individual and corporate names where material showed beneficiaries of laundering through corporate vehicles.
Provisional attachment under the PMLA was confirmed on the basis that cumulative material - statements under section 50(2) PMLA, searches, bank and property linkages and a disclosed modus operandi - established receipt and layering of proceeds of crime, with a statement under the Income Tax Act admitted only as corroboration. Objection that Regulation 3 language requirements were breached was rejected on factual findings that English translations and gists were furnished and witnesses understood Bengali. The Tribunal construed provisional attachment as permissible during investigation or related proceedings and upheld attachment of assets in individual and corporate names where material showed beneficiaries of laundering through corporate vehicles.
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