Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
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Regular bail under the PMLA was granted where Section 45's twin conditions had to be read with Article 21. The Court noted that investigation against the applicant was complete, the prosecution complaint had been filed, cognizance taken, and the matter remained at the stage of scrutiny and supply of documents. As the predicate FIR was old, no chargesheet had been filed in that offence, and there was no realistic prospect of the trial beginning or ending within a reasonable time, continued custody was held unjustified. The documentary nature of the material already collected also supported bail, which was made subject to conditions.
Regular bail under the PMLA was granted where Section 45's twin conditions had to be read with Article 21. The Court noted that investigation against the applicant was complete, the prosecution complaint had been filed, cognizance taken, and the matter remained at the stage of scrutiny and supply of documents. As the predicate FIR was old, no chargesheet had been filed in that offence, and there was no realistic prospect of the trial beginning or ending within a reasonable time, continued custody was held unjustified. The documentary nature of the material already collected also supported bail, which was made subject to conditions.
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