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...
Allegations concerning foreign investment in digital news media, share pricing and use of funds did not disclose cheating, criminal breach of trust or conspiracy. The Court held that online publication was not print media, no relevant cap on foreign investment applied at the time, and share valuation was made through a chartered accountant in line with FEMA fair-value requirements, with the final price reflecting a negotiated economic decision. It found no deception, entrustment or misappropriation, and no material showing an illegal agreement or scheduled offence. As the FIR did not disclose offences under Sections 406, 420 or 120B IPC, it was quashed and the linked ECIR under the PMLA also fell for want of a surviving predicate offence.
Allegations concerning foreign investment in digital news media, share pricing and use of funds did not disclose cheating, criminal breach of trust or conspiracy. The Court held that online publication was not print media, no relevant cap on foreign investment applied at the time, and share valuation was made through a chartered accountant in line with FEMA fair-value requirements, with the final price reflecting a negotiated economic decision. It found no deception, entrustment or misappropriation, and no material showing an illegal agreement or scheduled offence. As the FIR did not disclose offences under Sections 406, 420 or 120B IPC, it was quashed and the linked ECIR under the PMLA also fell for want of a surviving predicate offence.
Note: It is a system-generated summary and is for quick reference only.