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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Provisional attachment under money-laundering law was examined on the quantification of proceeds of crime, tracing of tainted funds, and the sufficiency of reasons to believe. The Tribunal upheld the computation, finding that the attachment order explained the basis of recovery and that the appellant's requested deductions were unsupported or already accounted for in the quantified amount. It also accepted that the statutory reverse burden required the person concerned to explain the source of property after notice under Section 8(1), and rejected the challenge under Section 5(1) because the reasons for attachment were reflected in the order and supporting material. The order was treated as speaking, and the appeal was dismissed.
Provisional attachment under money-laundering law was examined on the quantification of proceeds of crime, tracing of tainted funds, and the sufficiency of reasons to believe. The Tribunal upheld the computation, finding that the attachment order explained the basis of recovery and that the appellant's requested deductions were unsupported or already accounted for in the quantified amount. It also accepted that the statutory reverse burden required the person concerned to explain the source of property after notice under Section 8(1), and rejected the challenge under Section 5(1) because the reasons for attachment were reflected in the order and supporting material. The order was treated as speaking, and the appeal was dismissed.
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