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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Bail applications filed u/s 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, for offenses punishable u/ss 132 and 135 of the Customs Act, 1962, involving conscious possession of 1875.91 grams of gold paste concealed in five capsules. Held that as the petitioners have been in judicial custody for 61 days, investigation is incomplete, alleged offenses are punishable up to ten years, and the Investigating Officer has not filed the complaint, the petitioners are entitled to compulsive bail u/s 167(2) of the Code. Applications allowed, directing release of petitioners on bail upon executing a bond of Rs.1,00,000/- with two solvent sureties each for the like sum, subject to conditions imposed by the court having jurisdiction.
Bail applications filed u/s 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, for offenses punishable u/ss 132 and 135 of the Customs Act, 1962, involving conscious possession of 1875.91 grams of gold paste concealed in five capsules. Held that as the petitioners have been in judicial custody for 61 days, investigation is incomplete, alleged offenses are punishable up to ten years, and the Investigating Officer has not filed the complaint, the petitioners are entitled to compulsive bail u/s 167(2) of the Code. Applications allowed, directing release of petitioners on bail upon executing a bond of Rs.1,00,000/- with two solvent sureties each for the like sum, subject to conditions imposed by the court having jurisdiction.
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