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...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Non-bailable warrants - Apprehension for taking into custody - Recovery of taxes - It is well settled that custodial interrogation is qualitatively more elicitation oriented than questioning a suspect who is well ensconded with a favourable order under Section 438 of the code. In such cases effective interrogation of suspected person(s) is of tremendous advantage in disintering many useful informations and also materials which would have been concealed. - The prayer for interim protection to the petitioner during the pendency of the investigation, cannot be accepted - HC
Non-bailable warrants - Apprehension for taking into custody - Recovery of taxes - It is well settled that custodial interrogation is qualitatively more elicitation oriented than questioning a suspect who is well ensconded with a favourable order under Section 438 of the code. In such cases effective interrogation of suspected person(s) is of tremendous advantage in disintering many useful informations and also materials which would have been concealed. - The prayer for interim protection to the petitioner during the pendency of the investigation, cannot be accepted - HC
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