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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The HC dismissed the appeal challenging PMLA 2002 proceedings jurisdiction. Appellants argued that offences committed between June 2005-2007 preceded the Act's June 2009 amendment, rendering proceedings invalid. The court held that appellants continued dealing with immovable properties and crime proceeds post-amendment, establishing jurisdiction. Regarding pecuniary limits, the court determined that proceedings under Section 2(1)(y) Clause (i) require no minimum value threshold. Additionally, the crime proceeds exceeding Rs. 5.24 crores surpassed both pre and post-amendment limits of Rs. 30 lakhs. The court clarified that pecuniary jurisdiction depends on fraud quantum rather than property values, and since alleged offences fall under Schedule Part-A rather than Part-B, pecuniary limitations are inapplicable.
The HC dismissed the appeal challenging PMLA 2002 proceedings jurisdiction. Appellants argued that offences committed between June 2005-2007 preceded the Act's June 2009 amendment, rendering proceedings invalid. The court held that appellants continued dealing with immovable properties and crime proceeds post-amendment, establishing jurisdiction. Regarding pecuniary limits, the court determined that proceedings under Section 2(1)(y) Clause (i) require no minimum value threshold. Additionally, the crime proceeds exceeding Rs. 5.24 crores surpassed both pre and post-amendment limits of Rs. 30 lakhs. The court clarified that pecuniary jurisdiction depends on fraud quantum rather than property values, and since alleged offences fall under Schedule Part-A rather than Part-B, pecuniary limitations are inapplicable.
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