Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
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Recording pre-charge evidence in a GST prosecution without a formal order summoning the accused is procedurally erroneous. The trial court must first follow the prescribed process, including the hearing requirement before taking cognizance under Section 223 of the BNSS and the applicable Supreme Court principles. Orders recording pre-charge evidence without compliance were set aside, and the trial court was directed to proceed under the statutory procedure.
Recording pre-charge evidence in a GST prosecution without a formal order summoning the accused is procedurally erroneous. The trial court must first follow the prescribed process, including the hearing requirement before taking cognizance under Section 223 of the BNSS and the applicable Supreme Court principles. Orders recording pre-charge evidence without compliance were set aside, and the trial court was directed to proceed under the statutory procedure.
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