Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
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In PMLA bail matters, the prosecution must show a prima facie scheduled offence and identify specific proceeds of crime; unaccounted income alone is insufficient. The Court found the alleged Himachal Pradesh scheduled offences had ended in cancellation reports, with no independent material sustaining them, and the complaint did not identify any specific property of the applicant as proceeds of crime from the Uttar Pradesh allegations. It also held that continued custody was unjustified because investigation was complete, trial would take time, and parity with a co-accused favoured release, so Article 21 concerns outweighed the bail restrictions. Bail was granted subject to conditions.
In PMLA bail matters, the prosecution must show a prima facie scheduled offence and identify specific proceeds of crime; unaccounted income alone is insufficient. The Court found the alleged Himachal Pradesh scheduled offences had ended in cancellation reports, with no independent material sustaining them, and the complaint did not identify any specific property of the applicant as proceeds of crime from the Uttar Pradesh allegations. It also held that continued custody was unjustified because investigation was complete, trial would take time, and parity with a co-accused favoured release, so Article 21 concerns outweighed the bail restrictions. Bail was granted subject to conditions.
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