Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Money Laundering - predicate/scheduled offence - proceeds of crime - purchase of papers of Rajasthan Eligibility Examination for Teachers, 2021 (REET, 2021) and its further distribution - As far as applicability of proviso appended to Section 45 (1) of the PMLA is concerned, the above facts clearly show that the amount recovered from the above persons as proceeds of crime is more than Rs. 1 Crore, therefore, the case of the present petitioner does not fall within the ambit of proviso appended to Section 45 (1) of PMLA. - Bail application rejected by the High Court.
Money Laundering - predicate/scheduled offence - proceeds of crime - purchase of papers of Rajasthan Eligibility Examination for Teachers, 2021 (REET, 2021) and its further distribution - As far as applicability of proviso appended to Section 45 (1) of the PMLA is concerned, the above facts clearly show that the amount recovered from the above persons as proceeds of crime is more than Rs. 1 Crore, therefore, the case of the present petitioner does not fall within the ambit of proviso appended to Section 45 (1) of PMLA. - Bail application rejected by the High Court.
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