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...
Seeking grant of Regular Bail - fraudulent transfer of ITC - The offence is triable by learned Magistrial Court. Denial of bail to the applicant, would amount to pretrial conviction. It is not that the applicant would flee from the trial. The apprehension of repetition of offence can be taken care by some stringent conditions. There is no justifiable ground to keep the present applicant in the judicial custody till the completion of investigation / trial. - Bail granted - DSC
Seeking grant of Regular Bail - fraudulent transfer of ITC - The offence is triable by learned Magistrial Court. Denial of bail to the applicant, would amount to pretrial conviction. It is not that the applicant would flee from the trial. The apprehension of repetition of offence can be taken care by some stringent conditions. There is no justifiable ground to keep the present applicant in the judicial custody till the completion of investigation / trial. - Bail granted - DSC
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