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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The High Court dismissed the writ petition challenging the Enforcement Case Information Report (ECIR) filed by the Enforcement Directorate (ED) under the Prevention of Money Laundering Act (PMLA), 2002. The court held that the definition of 'money laundering' u/s 3 of the PMLA is wide and expansive, covering not only direct involvement but also assistance or being a party to the process connected with proceeds of crime. Even if some FIRs are quashed or closed, the investigation under the same ECIR can continue as per Explanation II to Section 44. The ED, as an investigating agency, can proceed with the investigation initiated through the ECIR filed in 2022, despite the closure of certain FIRs. The court found no merit in the writ petition and dismissed it.
The High Court dismissed the writ petition challenging the Enforcement Case Information Report (ECIR) filed by the Enforcement Directorate (ED) under the Prevention of Money Laundering Act (PMLA), 2002. The court held that the definition of 'money laundering' u/s 3 of the PMLA is wide and expansive, covering not only direct involvement but also assistance or being a party to the process connected with proceeds of crime. Even if some FIRs are quashed or closed, the investigation under the same ECIR can continue as per Explanation II to Section 44. The ED, as an investigating agency, can proceed with the investigation initiated through the ECIR filed in 2022, despite the closure of certain FIRs. The court found no merit in the writ petition and dismissed it.
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