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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Seeking grant of bail - Money Laundering - remitting of funds abroad by using forged and fabricated documents - There is no property which is derived or obtained directly or indirectly as a result of criminal activity concerning the scheduled offence which can be regarded as ‘proceeds of crime’. There is legal force in the arguments advanced by the counsel for the petitioner that the unauthorized outward remittance by forged Form 15CB Certificates does not amount to ‘proceeds of crime’ being generated from the scheduled offence i.e. fabrication of Form 15CB Certificates. - HC
Seeking grant of bail - Money Laundering - remitting of funds abroad by using forged and fabricated documents - There is no property which is derived or obtained directly or indirectly as a result of criminal activity concerning the scheduled offence which can be regarded as ‘proceeds of crime’. There is legal force in the arguments advanced by the counsel for the petitioner that the unauthorized outward remittance by forged Form 15CB Certificates does not amount to ‘proceeds of crime’ being generated from the scheduled offence i.e. fabrication of Form 15CB Certificates. - HC
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