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 - Seeking quashing and setting aside of the Look Out Circular (LOC) - The Bombay High Court quashed the LOC issued by the ED against the petitioner, highlighting procedural lapses and the absence of material evidence. The court emphasized the petitioner's compliance with the investigation despite travel restrictions due to the COVID-19 pandemic. The judgment underscores the necessity for adherence to procedural guidelines in issuing LOCs and protecting individuals' rights against arbitrary detention. The court provided clear directives to ensure the petitioner's continued cooperation with the investigation while safeguarding his right to livelihood.
Money Laundering - Seeking quashing and setting aside of the Look Out Circular (LOC) - The Bombay High Court quashed the LOC issued by the ED against the petitioner, highlighting procedural lapses and the absence of material evidence. The court emphasized the petitioner's compliance with the investigation despite travel restrictions due to the COVID-19 pandemic. The judgment underscores the necessity for adherence to procedural guidelines in issuing LOCs and protecting individuals' rights against arbitrary detention. The court provided clear directives to ensure the petitioner's continued cooperation with the investigation while safeguarding his right to livelihood.
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