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 writ petitions challenging the provisional attachment order (PAO) and show cause notice (SCN) issued under the PMLA, holding them to be legally sustainable. It ruled the petitions were not maintainable in view of an efficacious alternative statutory remedy of appeal, and none of the limited contingencies justifying writ interference under Art. 226 of the COI were established. The HC found sufficient material for the Directorate and Adjudicating Authority (AA) to form the requisite "reason to believe," and held the attached properties constituted "proceeds of crime" arising from scheduled offences linked to an international cricket betting racket. The AA's composition and issuance of SCN, even absent prior attachment, were held valid. All petitions by A were dismissed.
The HC dismissed the writ petitions challenging the provisional attachment order (PAO) and show cause notice (SCN) issued under the PMLA, holding them to be legally sustainable. It ruled the petitions were not maintainable in view of an efficacious alternative statutory remedy of appeal, and none of the limited contingencies justifying writ interference under Art. 226 of the COI were established. The HC found sufficient material for the Directorate and Adjudicating Authority (AA) to form the requisite "reason to believe," and held the attached properties constituted "proceeds of crime" arising from scheduled offences linked to an international cricket betting racket. The AA's composition and issuance of SCN, even absent prior attachment, were held valid. All petitions by A were dismissed.
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