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 held that the eviction notice under Section 8(4) of PMLA is valid and within jurisdiction. The court found that non-compliance with Rule 5(1) does not vitiate the notice under Rule 5(2), as these provisions serve different purposes. The lack of a mandatory time limit for issuing the notice does not invalidate it. The court directed the Appellate Tribunal to expeditiously hear the petitioner's appeal and stay application within two months, effectively dismissing the petitioner's challenge as premature given the pending appeal.
HC held that the eviction notice under Section 8(4) of PMLA is valid and within jurisdiction. The court found that non-compliance with Rule 5(1) does not vitiate the notice under Rule 5(2), as these provisions serve different purposes. The lack of a mandatory time limit for issuing the notice does not invalidate it. The court directed the Appellate Tribunal to expeditiously hear the petitioner's appeal and stay application within two months, effectively dismissing the petitioner's challenge as premature given the pending appeal.
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