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...
Criminal conspiracy - deceive the banks - committing a criminal breach of trust and faith - vicarious liability - It is submitted that Petitioner were never being the Director of the accused companies - In order to constitute the offence, the intention to deceive should be in existence at the time when the inducement was made - on a perusal of the complaint and material, comes to a conclusion that the allegations levelled in the complaint on the face of it does not constitute any offence as against the petitioners. - HC
Criminal conspiracy - deceive the banks - committing a criminal breach of trust and faith - vicarious liability - It is submitted that Petitioner were never being the Director of the accused companies - In order to constitute the offence, the intention to deceive should be in existence at the time when the inducement was made - on a perusal of the complaint and material, comes to a conclusion that the allegations levelled in the complaint on the face of it does not constitute any offence as against the petitioners. - HC
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