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 denied satisfaction on the twin conditions under s.45, PMLA, finding prima facie involvement of the petitioner in layering and laundering as supported by a co-accused's s.50 statement and corroborative material, but granted bail on constitutional grounds of speedy trial. The petitioner, detained ~11 months against a maximum sentence of seven years and facing a protracted trial requiring 79 witnesses and 149 documents (27,639 pages), is released on bail upon furnishing a bond of Rs.10,000 with two sureties of like amount to the satisfaction of the learned Sessions Judge-cum-Special Judge (PMLA), Patna, subject to conditions under s.437(3), CrPC and s.480(3), BNSS.
HC denied satisfaction on the twin conditions under s.45, PMLA, finding prima facie involvement of the petitioner in layering and laundering as supported by a co-accused's s.50 statement and corroborative material, but granted bail on constitutional grounds of speedy trial. The petitioner, detained ~11 months against a maximum sentence of seven years and facing a protracted trial requiring 79 witnesses and 149 documents (27,639 pages), is released on bail upon furnishing a bond of Rs.10,000 with two sureties of like amount to the satisfaction of the learned Sessions Judge-cum-Special Judge (PMLA), Patna, subject to conditions under s.437(3), CrPC and s.480(3), BNSS.
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