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 application challenging the freezing orders issued by the Enforcement Directorate u/s 17 and Section 17(1-A) of the Prevention of Money Laundering Act (PMLA), 2002. The Court held that the phrase "for the purposes of investigation" in the notice u/s 17(1-A) was sufficient justification for the Enforcement Directorate's actions. The Court distinguished the present case from the decisions relied upon by the petitioner, stating that the factual circumstances were different. The Court also clarified the difference between the implementation of Section 17(1-A) and Section 17(2) of the PMLA, emphasizing the requirement of maintaining secrecy u/s 17(2). Based on the financial trail linking the petitioner company to an entity under investigation, the Court found no grounds to interfere with the freezing orders.
The High Court dismissed the application challenging the freezing orders issued by the Enforcement Directorate u/s 17 and Section 17(1-A) of the Prevention of Money Laundering Act (PMLA), 2002. The Court held that the phrase "for the purposes of investigation" in the notice u/s 17(1-A) was sufficient justification for the Enforcement Directorate's actions. The Court distinguished the present case from the decisions relied upon by the petitioner, stating that the factual circumstances were different. The Court also clarified the difference between the implementation of Section 17(1-A) and Section 17(2) of the PMLA, emphasizing the requirement of maintaining secrecy u/s 17(2). Based on the financial trail linking the petitioner company to an entity under investigation, the Court found no grounds to interfere with the freezing orders.
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