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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Shares held in a demat account were treated as property acquired from proceeds of crime where the appellant, a Data Entry Operator on a modest salary, had received funds from an entity linked to alleged diversion of money and could not substantiate her claim that the transfer was a one-time family medical help. The bank records showed the amount was used to purchase shares of M/s CGPISL, which remained in the demat account. The Appellate Tribunal found no illegality in the provisional attachment merely because the appellant was not named in the FIR and upheld the attachment of the shares. The appeal was dismissed.
Shares held in a demat account were treated as property acquired from proceeds of crime where the appellant, a Data Entry Operator on a modest salary, had received funds from an entity linked to alleged diversion of money and could not substantiate her claim that the transfer was a one-time family medical help. The bank records showed the amount was used to purchase shares of M/s CGPISL, which remained in the demat account. The Appellate Tribunal found no illegality in the provisional attachment merely because the appellant was not named in the FIR and upheld the attachment of the shares. The appeal was dismissed.
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