Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Filing of a charge-sheet, pendency of sanction against another accused, a long witness list, or anticipated trial delay do not by themselves justify bail in a corruption conspiracy case. The Court found a prima facie chain of circumstantial evidence linking the applicant to demand and facilitation of illegal gratification, including intercepted communications, presence at the transfer meeting, recovery of firm records near his residence, and the prosecution case that the recovered amount was the share of all accused. It rejected the plea that liability lay only with the co-accused who physically carried the money, holding that prima facie conspiracy and facilitation can sustain prosecution even without direct receipt of the bribe. Bail was refused.
Filing of a charge-sheet, pendency of sanction against another accused, a long witness list, or anticipated trial delay do not by themselves justify bail in a corruption conspiracy case. The Court found a prima facie chain of circumstantial evidence linking the applicant to demand and facilitation of illegal gratification, including intercepted communications, presence at the transfer meeting, recovery of firm records near his residence, and the prosecution case that the recovered amount was the share of all accused. It rejected the plea that liability lay only with the co-accused who physically carried the money, holding that prima facie conspiracy and facilitation can sustain prosecution even without direct receipt of the bribe. Bail was refused.
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