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, exercising jurisdiction under PMLA, upheld the legality of the petitioner's arrest under s.19, noting proper recording and communication of "reasons to believe" and service of written grounds of arrest, duly acknowledged by the petitioner. On culpability, HC found prima facie material in the prosecution complaint and statements recorded under s.50 indicating that the petitioner directly participated in money laundering activities involving use, acquisition, possession, concealment and projection of proceeds of crime as untainted. Applying ss.19, 45(1) and 45(2), HC held the stringent twin conditions for bail were not satisfied, given the gravity of the economic offence, sophisticated modus operandi, and substantial loss to the exchequer. Finding no exceptional circumstances, HC dismissed the bail application.
HC, exercising jurisdiction under PMLA, upheld the legality of the petitioner's arrest under s.19, noting proper recording and communication of "reasons to believe" and service of written grounds of arrest, duly acknowledged by the petitioner. On culpability, HC found prima facie material in the prosecution complaint and statements recorded under s.50 indicating that the petitioner directly participated in money laundering activities involving use, acquisition, possession, concealment and projection of proceeds of crime as untainted. Applying ss.19, 45(1) and 45(2), HC held the stringent twin conditions for bail were not satisfied, given the gravity of the economic offence, sophisticated modus operandi, and substantial loss to the exchequer. Finding no exceptional circumstances, HC dismissed the bail application.
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