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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A provisional attachment under money laundering law was sustained because the appellants failed to prove the lawful source of the attached properties. The Tribunal found that claims regarding a brother's purchase and gift of a flat, and properties held by the wife, son, and family entities, were unsupported by satisfactory documentary material. Income-tax returns, registered deeds, and assertions of subcontract work were held insufficient where bank entries, summons responses, and proof of actual business activity did not establish genuine acquisition sources. On that basis, the Tribunal accepted that the entities were used to layer and project tainted funds as untainted and found no perversity in the order confirming attachment.
A provisional attachment under money laundering law was sustained because the appellants failed to prove the lawful source of the attached properties. The Tribunal found that claims regarding a brother's purchase and gift of a flat, and properties held by the wife, son, and family entities, were unsupported by satisfactory documentary material. Income-tax returns, registered deeds, and assertions of subcontract work were held insufficient where bank entries, summons responses, and proof of actual business activity did not establish genuine acquisition sources. On that basis, the Tribunal accepted that the entities were used to layer and project tainted funds as untainted and found no perversity in the order confirming attachment.
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