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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Rule 5(5) of the 2013 Rules permits acceptance of a fixed deposit in substitution for attached jointly owned immovable property only to the extent of the concerned person's estimated share. Its discretionary wording does not create a general or enforceable right to secure release of PMLA-attached property by offering equivalent security; financial hardship and adequacy of security do not justify mandamus. Writ jurisdiction under Article 226 should not ordinarily bypass the PMLA appellate mechanism where no exceptional circumstance, natural justice breach, jurisdictional error, perversity, or manifest illegality is shown. The writ petition was dismissed, leaving the validity of attachment for the pending statutory appeals.
Rule 5(5) of the 2013 Rules permits acceptance of a fixed deposit in substitution for attached jointly owned immovable property only to the extent of the concerned person's estimated share. Its discretionary wording does not create a general or enforceable right to secure release of PMLA-attached property by offering equivalent security; financial hardship and adequacy of security do not justify mandamus. Writ jurisdiction under Article 226 should not ordinarily bypass the PMLA appellate mechanism where no exceptional circumstance, natural justice breach, jurisdictional error, perversity, or manifest illegality is shown. The writ petition was dismissed, leaving the validity of attachment for the pending statutory appeals.
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TaxTMI 
TaxTMI 
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