Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Validity of search - it was necessary to conduct search under Section 17 of PMLA in the premises mentioned in the note; to identify and seize available incriminating record/documents relating to the predicate offence and to the offence of money laundering; relating to the whereabouts of the proceeds of crime; to identify and trace the proceeds of crime; to recover incriminating documents relating to commission of the offence of money laundering. - Single Judge had erred in holding that no reasons to believe were recorded - Search action validated - HC
Validity of search - it was necessary to conduct search under Section 17 of PMLA in the premises mentioned in the note; to identify and seize available incriminating record/documents relating to the predicate offence and to the offence of money laundering; relating to the whereabouts of the proceeds of crime; to identify and trace the proceeds of crime; to recover incriminating documents relating to commission of the offence of money laundering. - Single Judge had erred in holding that no reasons to believe were recorded - Search action validated - HC
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