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 Prevention of Money Laundering Act was confirmed where seized institutional records, mark sheet registers and corroborative documentary information established large scale issuance of forged degrees and diversion of funds as proceeds of crime; appellants served notice under section 8(1) failed to satisfactorily disclose legitimate sources for attached movable and immovable properties, so the attachment was sustained. The absence of recovery of individual forged degree certificates did not negate the seizure-based foundation for attachment. Documents filed in rejoinder amounted to new evidence and were inadmissible without formal application and Tribunal permission; appeals dismissed.
Provisional attachment under the Prevention of Money Laundering Act was confirmed where seized institutional records, mark sheet registers and corroborative documentary information established large scale issuance of forged degrees and diversion of funds as proceeds of crime; appellants served notice under section 8(1) failed to satisfactorily disclose legitimate sources for attached movable and immovable properties, so the attachment was sustained. The absence of recovery of individual forged degree certificates did not negate the seizure-based foundation for attachment. Documents filed in rejoinder amounted to new evidence and were inadmissible without formal application and Tribunal permission; appeals dismissed.
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