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 allowed the petition, quashing and setting aside the transfer order dated 20.2.2025 by the PD&SJ which had moved Criminal Case No.1/2023 away from the Special Court designated under the PMLA. The court held the PD&SJ ignored mandatory PMLA provisions and denied the petitioner opportunity of hearing; Section 44(1) PMLA governs territorial jurisdiction of the Special Court and Sections 46(1)/65 preserve applicable CrPC provisions. Consequentially Criminal Case No.1/2023 is directed to be re-transferred to the Special Court constituted under the PMLA for trial, and the petition was allowed.
The HC allowed the petition, quashing and setting aside the transfer order dated 20.2.2025 by the PD&SJ which had moved Criminal Case No.1/2023 away from the Special Court designated under the PMLA. The court held the PD&SJ ignored mandatory PMLA provisions and denied the petitioner opportunity of hearing; Section 44(1) PMLA governs territorial jurisdiction of the Special Court and Sections 46(1)/65 preserve applicable CrPC provisions. Consequentially Criminal Case No.1/2023 is directed to be re-transferred to the Special Court constituted under the PMLA for trial, and the petition was allowed.
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