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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The HC allowed the appeal, set aside the impugned Single Judge judgment and upheld the Directorate’s provisional attachment order under Section 5 of the PMLA. The Court held the allocation letter to constitute “property” within Section 2(1)(v) and that misrepresentation in obtaining the allocation generated “proceeds of crime” under Section 2(1)(u), thereby attracting an offence under Section 3; continued possession, utilisation and monetisation of the coal constituted ongoing laundering. The HC rejected a pre-allocation temporal cutoff and affirmed the Directorate’s jurisdiction to attach the quantified value of extracted coal where a prima facie nexus to predicate offences and proceeds was established and the respondent failed to rebut the presumption of taint.
The HC allowed the appeal, set aside the impugned Single Judge judgment and upheld the Directorate’s provisional attachment order under Section 5 of the PMLA. The Court held the allocation letter to constitute “property” within Section 2(1)(v) and that misrepresentation in obtaining the allocation generated “proceeds of crime” under Section 2(1)(u), thereby attracting an offence under Section 3; continued possession, utilisation and monetisation of the coal constituted ongoing laundering. The HC rejected a pre-allocation temporal cutoff and affirmed the Directorate’s jurisdiction to attach the quantified value of extracted coal where a prima facie nexus to predicate offences and proceeds was established and the respondent failed to rebut the presumption of taint.
Note: It is a system-generated summary and is for quick reference only.