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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HC denied bail in money laundering case involving spurious anti-cancer medicine manufacturing scheme. Despite applicant's claim for exemption under Rs. 1 crore threshold per Section 45 PMLA proviso, court found scheme's total value exceeded this limit. Court applied twin conditions under Section 45 PMLA and statutory presumption under Section 24. Evidentiary materials including Section 50 PMLA statements, financial records, and WhatsApp communications demonstrated applicant's involvement in proceeds of crime. Applicant failed to rebut presumption of guilt or satisfy bail conditions. Court emphasized admissibility of Section 50 statements as judicial proceedings, rejecting constitutional challenge. Given ongoing investigation and supplementary prosecution complaint, bail application dismissed.
HC denied bail in money laundering case involving spurious anti-cancer medicine manufacturing scheme. Despite applicant's claim for exemption under Rs. 1 crore threshold per Section 45 PMLA proviso, court found scheme's total value exceeded this limit. Court applied twin conditions under Section 45 PMLA and statutory presumption under Section 24. Evidentiary materials including Section 50 PMLA statements, financial records, and WhatsApp communications demonstrated applicant's involvement in proceeds of crime. Applicant failed to rebut presumption of guilt or satisfy bail conditions. Court emphasized admissibility of Section 50 statements as judicial proceedings, rejecting constitutional challenge. Given ongoing investigation and supplementary prosecution complaint, bail application dismissed.
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