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 directed formation of Special Investigation Team (SIT) under CBI Zonal Director's supervision to investigate allegations of large-scale financial fraud, money laundering, and misappropriation of public funds. The case involved fraudulent activities through shell companies in tax havens, unsecured advances to subsidiaries, and creation of fictitious invoices spanning multiple jurisdictions including Mauritius, USA, Australia, and UAE. Given the magnitude of the alleged scam involving thousands of crores, multiple jurisdictions, nationalized banks, and international entities, the Court determined that neither EOW nor CBI alone could ensure fair investigation. The Court exercised its jurisdiction to order CBI investigation without State consent, citing national and international implications. Joint Director CBI (ACB) Mumbai to supervise the investigation.
HC directed formation of Special Investigation Team (SIT) under CBI Zonal Director's supervision to investigate allegations of large-scale financial fraud, money laundering, and misappropriation of public funds. The case involved fraudulent activities through shell companies in tax havens, unsecured advances to subsidiaries, and creation of fictitious invoices spanning multiple jurisdictions including Mauritius, USA, Australia, and UAE. Given the magnitude of the alleged scam involving thousands of crores, multiple jurisdictions, nationalized banks, and international entities, the Court determined that neither EOW nor CBI alone could ensure fair investigation. The Court exercised its jurisdiction to order CBI investigation without State consent, citing national and international implications. Joint Director CBI (ACB) Mumbai to supervise the investigation.
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