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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The text explains that the power to freeze property under Section 17(1A) of PMLA may be exercised where investigative material (FIR/ECIR and related records) provides reasons to believe funds are proceeds of crime and the claimant fails to explain source; in such cases freezing is justified. Retention for adjudication under Section 20(4) is supportable where prima facie involvement in money laundering exists and continued retention does not cause prejudice. A pre-existing lien or bank guarantee does not, by itself, prevent seizure or freezing when investigation indicates the property is implicated.
The text explains that the power to freeze property under Section 17(1A) of PMLA may be exercised where investigative material (FIR/ECIR and related records) provides reasons to believe funds are proceeds of crime and the claimant fails to explain source; in such cases freezing is justified. Retention for adjudication under Section 20(4) is supportable where prima facie involvement in money laundering exists and continued retention does not cause prejudice. A pre-existing lien or bank guarantee does not, by itself, prevent seizure or freezing when investigation indicates the property is implicated.
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