Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Inherent jurisdiction to quash criminal proceedings does not permit resolution of disputed factual defences concerning alleged wilful failure to furnish returns pursuant to search-assessment notices. Assertions that seized material was requested but not supplied, and that the default lacked wilfulness or mens rea, were disputed and lacked prima facie proof of requests before the stipulated period expired. Such matters require evidence and cannot be determined through a mini-trial at the quashing stage, where the Court assesses only whether a prima facie case exists. The quashing petitions were dismissed, leaving the Trial Court to decide the prosecutions on evidence without being influenced by the order's observations.
Inherent jurisdiction to quash criminal proceedings does not permit resolution of disputed factual defences concerning alleged wilful failure to furnish returns pursuant to search-assessment notices. Assertions that seized material was requested but not supplied, and that the default lacked wilfulness or mens rea, were disputed and lacked prima facie proof of requests before the stipulated period expired. Such matters require evidence and cannot be determined through a mini-trial at the quashing stage, where the Court assesses only whether a prima facie case exists. The quashing petitions were dismissed, leaving the Trial Court to decide the prosecutions on evidence without being influenced by the order's observations.
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