Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
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PMLA provisional attachment of an NBFC's bank balance requires material establishing that the property constitutes proceeds of crime connected with a scheduled offence. FIR allegations alone were insufficient where final chargesheets did not arraign the NBFC or its lending application, and no material showed that an unauthorised fintech operated under its licence or that the NBFC received identified criminal proceeds. Legitimate lending income and an outstanding contractual loan cannot be characterised as proceeds of crime without supporting evidence. As no nexus was identified between the attached balance and criminal proceeds, confirmation of the attachment was set aside.
PMLA provisional attachment of an NBFC's bank balance requires material establishing that the property constitutes proceeds of crime connected with a scheduled offence. FIR allegations alone were insufficient where final chargesheets did not arraign the NBFC or its lending application, and no material showed that an unauthorised fintech operated under its licence or that the NBFC received identified criminal proceeds. Legitimate lending income and an outstanding contractual loan cannot be characterised as proceeds of crime without supporting evidence. As no nexus was identified between the attached balance and criminal proceeds, confirmation of the attachment was set aside.
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