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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At the discharge stage under PMLA, the court must only see whether prosecution material, taken at face value, discloses the ingredients of money-laundering; it cannot conduct a mini-trial or weigh defence documents. Revisional interference with refusal of discharge is confined to patent illegality, jurisdictional error, or a legal bar to the proceedings. On the materials described, the assets, bank routing, deposits, insurance policies and investments were treated as sufficient to prima facie indicate acquisition, possession, layering and projection of proceeds of crime, and the accused's explanation was left for trial.
At the discharge stage under PMLA, the court must only see whether prosecution material, taken at face value, discloses the ingredients of money-laundering; it cannot conduct a mini-trial or weigh defence documents. Revisional interference with refusal of discharge is confined to patent illegality, jurisdictional error, or a legal bar to the proceedings. On the materials described, the assets, bank routing, deposits, insurance policies and investments were treated as sufficient to prima facie indicate acquisition, possession, layering and projection of proceeds of crime, and the accused's explanation was left for trial.
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