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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Attachment under the Act is not limited to property directly derived from the scheduled offence and may extend to property of equivalent value where the actual proceeds of crime are not traceable or available. The Tribunal held that, on the facts, unauthorized deposits were collected and diverted, and the tainted funds had been layered and siphoned off, justifying attachment of immovable properties standing in the appellants' names. It rejected the contention that property acquired before the offence is always immune, since that reading would make the statutory concept of value-equivalent attachment redundant. The challenge to the provisional attachment therefore failed and confirmation of attachment was sustained.
Attachment under the Act is not limited to property directly derived from the scheduled offence and may extend to property of equivalent value where the actual proceeds of crime are not traceable or available. The Tribunal held that, on the facts, unauthorized deposits were collected and diverted, and the tainted funds had been layered and siphoned off, justifying attachment of immovable properties standing in the appellants' names. It rejected the contention that property acquired before the offence is always immune, since that reading would make the statutory concept of value-equivalent attachment redundant. The challenge to the provisional attachment therefore failed and confirmation of attachment was sustained.
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