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 writ petitions and pending applications, refusing to direct a central agency investigation or SFIO involvement. The court found that alleged offences of fraud, cheating and money laundering arose from multiple independent franchise agreements with the respondent company and that FIRs and chargesheets have been registered by State Police in various States. Clubbing the matters was held likely to delay individual complainants' investigations; jurisdictional remedy lies before the respective High Courts or competent State courts. The HC noted ED has commenced PMLA inquiries and concluded no exceptional grounds existed to order SFIO or CBI takeover; consequently no further directions were granted.
The HC dismissed the writ petitions and pending applications, refusing to direct a central agency investigation or SFIO involvement. The court found that alleged offences of fraud, cheating and money laundering arose from multiple independent franchise agreements with the respondent company and that FIRs and chargesheets have been registered by State Police in various States. Clubbing the matters was held likely to delay individual complainants' investigations; jurisdictional remedy lies before the respective High Courts or competent State courts. The HC noted ED has commenced PMLA inquiries and concluded no exceptional grounds existed to order SFIO or CBI takeover; consequently no further directions were granted.
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