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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The High Court dismissed an anticipatory bail application u/s 438 CrPC in a smuggling case involving seizure of foreign-origin gold and cash. The applicant, claiming ownership of a gold business, failed to prove legitimacy of seized items. Lack of cooperation with DRI, non-response to summons, and absence of satisfactory explanations regarding cash and sales transactions led to rejection of bail. The economic nature of the offence, potential 7-year sentence, and insufficient evidence resulted in denial of anticipatory bail. Merely the submission that the seized items belong to the applicant and his firm and he is ready to pay the penalties and fee does not absolve the applicant from explaining with particularity regarding the huge quantum of cash, gold and ornaments record.
The High Court dismissed an anticipatory bail application u/s 438 CrPC in a smuggling case involving seizure of foreign-origin gold and cash. The applicant, claiming ownership of a gold business, failed to prove legitimacy of seized items. Lack of cooperation with DRI, non-response to summons, and absence of satisfactory explanations regarding cash and sales transactions led to rejection of bail. The economic nature of the offence, potential 7-year sentence, and insufficient evidence resulted in denial of anticipatory bail. Merely the submission that the seized items belong to the applicant and his firm and he is ready to pay the penalties and fee does not absolve the applicant from explaining with particularity regarding the huge quantum of cash, gold and ornaments record.
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