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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Territorial jurisdiction for a money-laundering offence may lie with any Special Court covering a local area where proceeds of crime are derived, obtained, concealed, possessed, acquired, used or projected as untainted property. The notes state that acquisition of alleged proceeds and attachment of related land at Gurugram made institution there competent, while concealment of proceeds attached at Delhi also created concurrent jurisdiction. Where the connected scheduled offence had been transferred to Delhi, transferring the PMLA proceeding there was considered expedient so that both matters could be tried by a Special Court having jurisdiction over the laundering offence. The proceeding was to continue at its existing stage.
Territorial jurisdiction for a money-laundering offence may lie with any Special Court covering a local area where proceeds of crime are derived, obtained, concealed, possessed, acquired, used or projected as untainted property. The notes state that acquisition of alleged proceeds and attachment of related land at Gurugram made institution there competent, while concealment of proceeds attached at Delhi also created concurrent jurisdiction. Where the connected scheduled offence had been transferred to Delhi, transferring the PMLA proceeding there was considered expedient so that both matters could be tried by a Special Court having jurisdiction over the laundering offence. The proceeding was to continue at its existing stage.
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