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 analyzed the interpretation of "nearest Magistrate" in money laundering arrest procedures. The court held that production before the jurisdictional Magistrate within 24 hours satisfies constitutional requirements under Article 22(2), and is not mandatorily restricted to geographically closest Magistrate. The arrest by ED under PMLA Section 19(1) was deemed valid, with procedural technicalities considered inadvertent omissions. The court emphasized that constitutional rights are violated only if an accused is detained beyond 24 hours without judicial production. The petitioner's challenge to detention was dismissed, affirming the legal validity of the arrest and subsequent remand proceedings.
HC analyzed the interpretation of "nearest Magistrate" in money laundering arrest procedures. The court held that production before the jurisdictional Magistrate within 24 hours satisfies constitutional requirements under Article 22(2), and is not mandatorily restricted to geographically closest Magistrate. The arrest by ED under PMLA Section 19(1) was deemed valid, with procedural technicalities considered inadvertent omissions. The court emphasized that constitutional rights are violated only if an accused is detained beyond 24 hours without judicial production. The petitioner's challenge to detention was dismissed, affirming the legal validity of the arrest and subsequent remand proceedings.
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