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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SC refused interlocutory relief and declined to quash cognizance or interdict ongoing proceedings under the PMLA, holding that the contention that the entire banking balance constituted "proceeds of crime" was unsustainable where transactions were routed through regular banking channels and reflected in books of account. The Court directed that the statutory process, including appellate review by the Appellate Tribunal, be permitted to run its course to determine whether the attached assets constitute "proceeds of crime" under Section 2(1)(u) and whether withdrawals contravened law. Allegations are presently confined to recovery of INR 33.80 Crore and do not presently establish criminal liability beyond the statutory process; appellants may pursue statutory appeals.
SC refused interlocutory relief and declined to quash cognizance or interdict ongoing proceedings under the PMLA, holding that the contention that the entire banking balance constituted "proceeds of crime" was unsustainable where transactions were routed through regular banking channels and reflected in books of account. The Court directed that the statutory process, including appellate review by the Appellate Tribunal, be permitted to run its course to determine whether the attached assets constitute "proceeds of crime" under Section 2(1)(u) and whether withdrawals contravened law. Allegations are presently confined to recovery of INR 33.80 Crore and do not presently establish criminal liability beyond the statutory process; appellants may pursue statutory appeals.
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