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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Anticipatory bail under the PMLA was considered against the twin test requiring reasonable grounds to believe the accused are not guilty and pose no likelihood of offending while on bail; the court found no such grounds and dismissed anticipatory bail. The court held custodial interrogation is necessary in complex, layered moneylaundering investigations involving mule accounts, transnational syndicates, risk of evidence destruction and alleged bribery, and that economic/socioeconomic offences require stricter bail scrutiny; the presumption regarding proceeds of crime under the PMLA weighed against bail. The HC balanced Article 21 liberty interests with investigatory needs and prioritized effective interrogation.
Anticipatory bail under the PMLA was considered against the twin test requiring reasonable grounds to believe the accused are not guilty and pose no likelihood of offending while on bail; the court found no such grounds and dismissed anticipatory bail. The court held custodial interrogation is necessary in complex, layered moneylaundering investigations involving mule accounts, transnational syndicates, risk of evidence destruction and alleged bribery, and that economic/socioeconomic offences require stricter bail scrutiny; the presumption regarding proceeds of crime under the PMLA weighed against bail. The HC balanced Article 21 liberty interests with investigatory needs and prioritized effective interrogation.
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