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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Money Laundering - illegal mining of granite, causing damages to human life and properties using explosives - scheduled offences - The High Court clarified that the Prevention of Money Laundering Act (PMLA) is a standalone legislation aimed at addressing money laundering activities, irrespective of the nature of the predicate offense. It affirmed that simultaneous investigation and prosecution under PMLA and the predicate offense are permissible. - The Court concluded that the prosecution failed to establish a direct link between the properties in question and the proceeds of the predicate offense. It found no evidence indicating that the accused persons were in possession or enjoyment of the properties acquired through illegal means. - Consequently, it quashed the complaint against certain accused persons, highlighting the lack of evidence connecting them to the alleged illegal activities.
Money Laundering - illegal mining of granite, causing damages to human life and properties using explosives - scheduled offences - The High Court clarified that the Prevention of Money Laundering Act (PMLA) is a standalone legislation aimed at addressing money laundering activities, irrespective of the nature of the predicate offense. It affirmed that simultaneous investigation and prosecution under PMLA and the predicate offense are permissible. - The Court concluded that the prosecution failed to establish a direct link between the properties in question and the proceeds of the predicate offense. It found no evidence indicating that the accused persons were in possession or enjoyment of the properties acquired through illegal means. - Consequently, it quashed the complaint against certain accused persons, highlighting the lack of evidence connecting them to the alleged illegal activities.
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