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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SC analyzed the duration of property attachment under PMLA Section 8(3), focusing on the applicability of legal provisions before and after amendment. The Court held that the original provision governs the attachment order, and the pendency of a complaint alleging money laundering offense is sufficient to maintain the attachment, irrespective of specific accused designation. The complaint's existence alone justifies continuing the property retention order. The SC set aside both the High Court and Appellate Tribunal orders, determining that the pre-amendment clause (a) applies, thereby allowing the attachment to remain in effect during ongoing legal proceedings related to the money laundering investigation.
SC analyzed the duration of property attachment under PMLA Section 8(3), focusing on the applicability of legal provisions before and after amendment. The Court held that the original provision governs the attachment order, and the pendency of a complaint alleging money laundering offense is sufficient to maintain the attachment, irrespective of specific accused designation. The complaint's existence alone justifies continuing the property retention order. The SC set aside both the High Court and Appellate Tribunal orders, determining that the pre-amendment clause (a) applies, thereby allowing the attachment to remain in effect during ongoing legal proceedings related to the money laundering investigation.
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