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 allowed the appeal and set aside the impugned AT order dated 26.06.2024, holding that the Respondent's continued retention of the Appellant's property was unlawful for non-compliance with Section 20 of the PMLA. The Court affirmed that Section 20(1) imposes a substantive, mandatory requirement of a fresh, independent, written "reason to believe" by an authorised officer post-seizure under Section 17, without which there is nothing for the Adjudicating Authority to confirm under Section 8(3)(a). While rejecting the Appellant's challenge to the application of Section 8(3)(a) in light of binding SC precedent, the HC concluded the retention violated Article 300A and could not be sustained.
HC allowed the appeal and set aside the impugned AT order dated 26.06.2024, holding that the Respondent's continued retention of the Appellant's property was unlawful for non-compliance with Section 20 of the PMLA. The Court affirmed that Section 20(1) imposes a substantive, mandatory requirement of a fresh, independent, written "reason to believe" by an authorised officer post-seizure under Section 17, without which there is nothing for the Adjudicating Authority to confirm under Section 8(3)(a). While rejecting the Appellant's challenge to the application of Section 8(3)(a) in light of binding SC precedent, the HC concluded the retention violated Article 300A and could not be sustained.
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