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 petition challenging arrest and consequential proceedings under the PMLA, holding that the impugned arrest was supported by the authorized officer's recorded "reason to believe" and by material in possession of the ED, and that alleged procedural lapses-including non-issuance of a Section 50 notice and an erroneous recital of "non-cooperation" in the grounds of arrest-constituted irregularities but not illegality. The Court underscored that Sections 19 and 50 serve distinct functions, Section 50 is not a precondition to arrest under Section 19, and disputed factual issues regarding necessity of custody, preservation of evidence and further investigation are matters for the trial forum or Special Court, not for writ relief. Petition dismissed.
The HC dismissed the petition challenging arrest and consequential proceedings under the PMLA, holding that the impugned arrest was supported by the authorized officer's recorded "reason to believe" and by material in possession of the ED, and that alleged procedural lapses-including non-issuance of a Section 50 notice and an erroneous recital of "non-cooperation" in the grounds of arrest-constituted irregularities but not illegality. The Court underscored that Sections 19 and 50 serve distinct functions, Section 50 is not a precondition to arrest under Section 19, and disputed factual issues regarding necessity of custody, preservation of evidence and further investigation are matters for the trial forum or Special Court, not for writ relief. Petition dismissed.
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