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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Seizure of large quantity of counterfeit Indian currency notes, determining ingredients u/s 489B of IPC. Interpretation of 'possessing', 'traffic', and 'otherwise trafficking in' terms. Reliance on previous judgments regarding active transportation and burden of proof u/s 106 of Evidence Act when no explanation offered. Appellant found in possession of 71 fake Rs. 500 notes at public place, failed to explain manner of obtaining them. Conviction u/ss 489B and 489C upheld, sentences modified to 5 years RI and Rs. 10,000 fine for 489B, 3 years RI and Rs. 5,000 fine for 489C. Appeal partly allowed by reducing sentences without interfering with conviction order.
Seizure of large quantity of counterfeit Indian currency notes, determining ingredients u/s 489B of IPC. Interpretation of 'possessing', 'traffic', and 'otherwise trafficking in' terms. Reliance on previous judgments regarding active transportation and burden of proof u/s 106 of Evidence Act when no explanation offered. Appellant found in possession of 71 fake Rs. 500 notes at public place, failed to explain manner of obtaining them. Conviction u/ss 489B and 489C upheld, sentences modified to 5 years RI and Rs. 10,000 fine for 489B, 3 years RI and Rs. 5,000 fine for 489C. Appeal partly allowed by reducing sentences without interfering with conviction order.
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