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 invalidated search and seizure operations conducted at petitioner's residence under PMLA, 2002. Court held that mere suspicion of money laundering without substantive evidence violates statutory procedural safeguards. Despite proper authorization from Joint Director, the search lacked "reason to believe" standard required under Section 17(1). No prima facie evidence established petitioner's involvement in predicate offense of illegal site allotments during MUDA commissioner tenure. Subsequent summons under Section 50 and recorded statements were quashed as they stemmed from illegal search. Court emphasized protection of liberty and privacy rights under Article 21, granting petitioner liberty to pursue action under Section 62 PMLA for vexatious search.
HC invalidated search and seizure operations conducted at petitioner's residence under PMLA, 2002. Court held that mere suspicion of money laundering without substantive evidence violates statutory procedural safeguards. Despite proper authorization from Joint Director, the search lacked "reason to believe" standard required under Section 17(1). No prima facie evidence established petitioner's involvement in predicate offense of illegal site allotments during MUDA commissioner tenure. Subsequent summons under Section 50 and recorded statements were quashed as they stemmed from illegal search. Court emphasized protection of liberty and privacy rights under Article 21, granting petitioner liberty to pursue action under Section 62 PMLA for vexatious search.
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