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 allowed the application for regular bail filed u/ss 45 and 46 of PMLA read with Section 439 CrPC in a case involving illegal excavation and theft of coal. The Court recognized the gravity of economic offences but balanced it with the accused's right to speedy trial under Article 21. Despite stringent bail conditions u/s 45 PMLA, the Court held that long incarceration of nearly 28 months and no possibility of early trial completion justified granting bail. The Court imposed stringent conditions like personal bond of Rs.5 lakh and sureties to allay apprehensions of flight risk. The investigation was complete, and evidence was documentary, mitigating tampering concerns. The bail application was allowed, subject to conditions.
The High Court allowed the application for regular bail filed u/ss 45 and 46 of PMLA read with Section 439 CrPC in a case involving illegal excavation and theft of coal. The Court recognized the gravity of economic offences but balanced it with the accused's right to speedy trial under Article 21. Despite stringent bail conditions u/s 45 PMLA, the Court held that long incarceration of nearly 28 months and no possibility of early trial completion justified granting bail. The Court imposed stringent conditions like personal bond of Rs.5 lakh and sureties to allay apprehensions of flight risk. The investigation was complete, and evidence was documentary, mitigating tampering concerns. The bail application was allowed, subject to conditions.
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