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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Construction of "proceeds of crime" and the offence under the PMLA was examined against allegations of large-scale illegal quarrying and related lease transactions; the court applied statutory definitions and precedents to hold that the complaint furnishes prima facie particulars linking the impugned property and lease dealings to laundering and thus discloses offences under the money laundering statute. Acquisition of property before the predicate offences was held not determinative where the complaint pleads subsequent use, transfer or lease for concealment and laundering. The extraordinary jurisdiction to quash was declined and the petition was dismissed; issues reserved for trial.
Construction of "proceeds of crime" and the offence under the PMLA was examined against allegations of large-scale illegal quarrying and related lease transactions; the court applied statutory definitions and precedents to hold that the complaint furnishes prima facie particulars linking the impugned property and lease dealings to laundering and thus discloses offences under the money laundering statute. Acquisition of property before the predicate offences was held not determinative where the complaint pleads subsequent use, transfer or lease for concealment and laundering. The extraordinary jurisdiction to quash was declined and the petition was dismissed; issues reserved for trial.
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