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 held that, as a "reporting entity" under the PMLA, the respondent bank may, based on suspicion of proceeds of crime, impose a temporary debit freeze on customer accounts under its contractual and statutory obligations, even absent a specific requisition from a law enforcement agency. However, such freezing must be reasonable and time-bound. The HC fixed a maximum reasonable period of three months for continuation of the debit freeze, during which law enforcement agencies must act. If no investigative or coercive action is initiated within this period, the bank must lift the freeze. The bank was directed to notify all specified authorities of the account freezing within two working days and to comply with the procedural guidelines set out in the judgment. The writ petitions were disposed of on these terms.
The HC held that, as a "reporting entity" under the PMLA, the respondent bank may, based on suspicion of proceeds of crime, impose a temporary debit freeze on customer accounts under its contractual and statutory obligations, even absent a specific requisition from a law enforcement agency. However, such freezing must be reasonable and time-bound. The HC fixed a maximum reasonable period of three months for continuation of the debit freeze, during which law enforcement agencies must act. If no investigative or coercive action is initiated within this period, the bank must lift the freeze. The bank was directed to notify all specified authorities of the account freezing within two working days and to comply with the procedural guidelines set out in the judgment. The writ petitions were disposed of on these terms.
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