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 a PAO was upheld on the basis that available investigative material, including recovered bribe money and an unquashed FIR, established a prima facie case of money laundering; the appellant's contention that no crime was committed was rejected. The Tribunal directed that attachment must be limited to quantifiable proceeds of crime rather than the entire contract value, recognising legitimate manufacturing costs and expenses. The respondent was ordered to quantify the recoverable proceeds (focusing on the profit/illicit portion) and reassess the provisional attachment within the specified four week period.
Provisional attachment under a PAO was upheld on the basis that available investigative material, including recovered bribe money and an unquashed FIR, established a prima facie case of money laundering; the appellant's contention that no crime was committed was rejected. The Tribunal directed that attachment must be limited to quantifiable proceeds of crime rather than the entire contract value, recognising legitimate manufacturing costs and expenses. The respondent was ordered to quantify the recoverable proceeds (focusing on the profit/illicit portion) and reassess the provisional attachment within the specified four week period.
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