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 tribunal upheld provisional attachment in a money-laundering matter after finding that the appellant could not justify retention of amounts received in land transactions. The earlier agreement to sell was rejected because it was unsigned on all pages and could not override the later registered sale deed showing a lower consideration; the excess amount was treated as proceeds of crime. The tribunal also held that, after cancellation of a sale agreement, retained funds required to be refunded could be attached as property of equivalent value, even if the attached assets had been acquired before the crime. Confirmation of the attachment was therefore sustained.
A tribunal upheld provisional attachment in a money-laundering matter after finding that the appellant could not justify retention of amounts received in land transactions. The earlier agreement to sell was rejected because it was unsigned on all pages and could not override the later registered sale deed showing a lower consideration; the excess amount was treated as proceeds of crime. The tribunal also held that, after cancellation of a sale agreement, retained funds required to be refunded could be attached as property of equivalent value, even if the attached assets had been acquired before the crime. Confirmation of the attachment was therefore sustained.
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