Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Money Laundering - Scheduled offences - The petitioners besides facing trial for the offences under ULA(P) Act, are also facing trial for offence under Section 121-A of RPC. The offence under Section 121-A of IPC, which is in pari materia with Section 121-A of the RPC, was a scheduled offence even prior to the Amendment Act of 2009. On this ground also, the petitioners cannot claim that they could not have been prosecuted for offence under Section 3 of the PMLA. - HC
Money Laundering - Scheduled offences - The petitioners besides facing trial for the offences under ULA(P) Act, are also facing trial for offence under Section 121-A of RPC. The offence under Section 121-A of IPC, which is in pari materia with Section 121-A of the RPC, was a scheduled offence even prior to the Amendment Act of 2009. On this ground also, the petitioners cannot claim that they could not have been prosecuted for offence under Section 3 of the PMLA. - HC
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