Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Wilful evasion of tax payment requires material showing circumstances and conduct from which a deliberate attempt to avoid payment can be inferred. Although culpable mental state may be presumed, delayed payment within the stipulated period alone does not establish the offence. Where the original assessment was acknowledged as erroneous and later modified, the delay was explained by financial constraints, and payment was made after receipt of a show-cause notice, the material indicates delayed payment rather than a wilful attempt to evade tax. On those facts, prosecution was treated as futile and an abuse of process, and the complaint was quashed.
Wilful evasion of tax payment requires material showing circumstances and conduct from which a deliberate attempt to avoid payment can be inferred. Although culpable mental state may be presumed, delayed payment within the stipulated period alone does not establish the offence. Where the original assessment was acknowledged as erroneous and later modified, the delay was explained by financial constraints, and payment was made after receipt of a show-cause notice, the material indicates delayed payment rather than a wilful attempt to evade tax. On those facts, prosecution was treated as futile and an abuse of process, and the complaint was quashed.
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