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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Seeking grant of pre-arrest bail - Territorial jurisdiction of court - supply of material/ goods without invoices to evade the tax - the corporate office of MEPL is at Noida and the investigation has been initiated by DGGI Zonal unit Jaipur but fact remains that applicant also operates through MEPL in Marketing Office of Delhi. Therefore it cannot be laid down as an absolute rule that Delhi court has no jurisdiction at all - In the reply filed by the DGGI Jaipur Zonal Unit, no specific amount has been mentioned about the tax evasion. - Protection granted - DSC
Seeking grant of pre-arrest bail - Territorial jurisdiction of court - supply of material/ goods without invoices to evade the tax - the corporate office of MEPL is at Noida and the investigation has been initiated by DGGI Zonal unit Jaipur but fact remains that applicant also operates through MEPL in Marketing Office of Delhi. Therefore it cannot be laid down as an absolute rule that Delhi court has no jurisdiction at all - In the reply filed by the DGGI Jaipur Zonal Unit, no specific amount has been mentioned about the tax evasion. - Protection granted - DSC
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