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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In PMLA bail matters, the prosecution must show a prima facie scheduled offence and identify specific proceeds of crime; unaccounted income alone is insufficient. The Court found the alleged Himachal Pradesh scheduled offences had ended in cancellation reports, with no independent material sustaining them, and the complaint did not identify any specific property of the applicant as proceeds of crime from the Uttar Pradesh allegations. It also held that continued custody was unjustified because investigation was complete, trial would take time, and parity with a co-accused favoured release, so Article 21 concerns outweighed the bail restrictions. Bail was granted subject to conditions.
In PMLA bail matters, the prosecution must show a prima facie scheduled offence and identify specific proceeds of crime; unaccounted income alone is insufficient. The Court found the alleged Himachal Pradesh scheduled offences had ended in cancellation reports, with no independent material sustaining them, and the complaint did not identify any specific property of the applicant as proceeds of crime from the Uttar Pradesh allegations. It also held that continued custody was unjustified because investigation was complete, trial would take time, and parity with a co-accused favoured release, so Article 21 concerns outweighed the bail restrictions. Bail was granted subject to conditions.
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