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 applicant's anticipatory bail application under Section 482 BNSS in a money laundering case involving forged Form 15CBs and remittances exceeding Rs. 300 crores. Though not named in the predicate FIR, the Enforcement Directorate attributed proceeds to the applicant's company under PMLA Sections 3 and 70. The Court held that statutory presumption under Section 24 PMLA arose, which the applicant failed to rebut. The applicant's evasive conduct, including non-compliance with multiple Section 50 summons despite being intercepted at Amritsar airport, demonstrated lack of bona fides. As a Hong Kong permanent resident with no fixed Indian assets, the applicant posed flight risk. The Court emphasized custodial interrogation necessity in white-collar crimes and found premature bail would impede investigation and compromise PMLA objectives.
The HC dismissed the applicant's anticipatory bail application under Section 482 BNSS in a money laundering case involving forged Form 15CBs and remittances exceeding Rs. 300 crores. Though not named in the predicate FIR, the Enforcement Directorate attributed proceeds to the applicant's company under PMLA Sections 3 and 70. The Court held that statutory presumption under Section 24 PMLA arose, which the applicant failed to rebut. The applicant's evasive conduct, including non-compliance with multiple Section 50 summons despite being intercepted at Amritsar airport, demonstrated lack of bona fides. As a Hong Kong permanent resident with no fixed Indian assets, the applicant posed flight risk. The Court emphasized custodial interrogation necessity in white-collar crimes and found premature bail would impede investigation and compromise PMLA objectives.
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