Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Quashment was refused where allegations of large-scale illegal mining, criminal conspiracy and connected PMLA laundering disclosed a prima facie case; disputed issues on valuation, quarried quantity, competing committee reports and the exact loss to the State were held to be matters for trial, not for threshold interference. The later committee report, prepared for damage assessment and not accepted for criminal liability, did not by itself end either the predicate offences or the PMLA complaint. Statements under Section 161 CrPC, claims of tutoring and the women partners' later retirement from the firm were also treated as trial issues, and the prosecution was allowed to continue.
Quashment was refused where allegations of large-scale illegal mining, criminal conspiracy and connected PMLA laundering disclosed a prima facie case; disputed issues on valuation, quarried quantity, competing committee reports and the exact loss to the State were held to be matters for trial, not for threshold interference. The later committee report, prepared for damage assessment and not accepted for criminal liability, did not by itself end either the predicate offences or the PMLA complaint. Statements under Section 161 CrPC, claims of tutoring and the women partners' later retirement from the firm were also treated as trial issues, and the prosecution was allowed to continue.
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