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...
Pre-arrest Bail Application - allegation of monthly amount were being paid as bribe to the officers and officials of taxation department. - There is no quibble that the liberty of a person is of utmost importance. But when personal liberty is pitted against a sovereign function i.e. collection of tax which is life blood of the economy, the latter would prevail. Present is a case where arrest is imperative for fair and full investigation. The petitioner being an exofficer of the department can influence the witness or temper with the evidence - no case is made out for grant of pre-arrest bail - HC
Pre-arrest Bail Application - allegation of monthly amount were being paid as bribe to the officers and officials of taxation department. - There is no quibble that the liberty of a person is of utmost importance. But when personal liberty is pitted against a sovereign function i.e. collection of tax which is life blood of the economy, the latter would prevail. Present is a case where arrest is imperative for fair and full investigation. The petitioner being an exofficer of the department can influence the witness or temper with the evidence - no case is made out for grant of pre-arrest bail - HC
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