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 Tribunal upheld attachment under the PMLA after finding valid service of the show cause notice, complaint and relied upon documents, and therefore no breach of natural justice or denial of hearing. It further held that property attached as proceeds of crime or the value thereof remains liable to attachment even if acquired before the alleged offence period, because the statute treats direct proceeds and their value alike. It also confirmed attachment of assets standing in a spouse's name or jointly held, holding that attachment is not limited to an accused in the scheduled offence but extends to any person involved in activity connected with proceeds of crime. Both appeals were dismissed.
The Tribunal upheld attachment under the PMLA after finding valid service of the show cause notice, complaint and relied upon documents, and therefore no breach of natural justice or denial of hearing. It further held that property attached as proceeds of crime or the value thereof remains liable to attachment even if acquired before the alleged offence period, because the statute treats direct proceeds and their value alike. It also confirmed attachment of assets standing in a spouse's name or jointly held, holding that attachment is not limited to an accused in the scheduled offence but extends to any person involved in activity connected with proceeds of crime. Both appeals were dismissed.
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