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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Provisional attachment under PMLA can extend to property of equivalent value where the original proceeds of crime are unavailable, even if the attached property was acquired before the alleged offence; the attachment was upheld on that basis. Pendency of a challenge to the predicate offence before the Supreme Court did not by itself invalidate the attachment, because the predicate offence had not been quashed and the interim stay did not extinguish it. The Tribunal also held that provisional attachment is not confined to a person formally named as an accused in the predicate offence, if the person is otherwise involved in the offence or is a recipient of proceeds of crime. The attachment was sustained, subject to the final outcome before the Supreme Court.
Provisional attachment under PMLA can extend to property of equivalent value where the original proceeds of crime are unavailable, even if the attached property was acquired before the alleged offence; the attachment was upheld on that basis. Pendency of a challenge to the predicate offence before the Supreme Court did not by itself invalidate the attachment, because the predicate offence had not been quashed and the interim stay did not extinguish it. The Tribunal also held that provisional attachment is not confined to a person formally named as an accused in the predicate offence, if the person is otherwise involved in the offence or is a recipient of proceeds of crime. The attachment was sustained, subject to the final outcome before the Supreme Court.
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