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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Grant of pre-arrest bail - case of applicant is that the applicant raised several contentions in the applications filed by them, however, all the contentions are not dealt with - principles of natural justice - It appears that learned advocate for the applicants has tried to re-argue the case by filing these applications for recalling of the order, which is not permissible. This Court is of the view that by way of filing these applications, applicants have indirectly requested this Court to review its own judgment, which is not permissible. - HC
Grant of pre-arrest bail - case of applicant is that the applicant raised several contentions in the applications filed by them, however, all the contentions are not dealt with - principles of natural justice - It appears that learned advocate for the applicants has tried to re-argue the case by filing these applications for recalling of the order, which is not permissible. This Court is of the view that by way of filing these applications, applicants have indirectly requested this Court to review its own judgment, which is not permissible. - HC
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