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...
The High Court quashed the criminal proceedings and cognizance orders against the petitioners for offenses u/ss 276B and 278B of the Income Tax Act. The TDS amount in question, which was the subject matter of the economic offense cases and C.O. Case, had already been deposited belatedly with interest to the Income Tax Department. The court held that continuing the proceedings would amount to an abuse of the process of law, given the deposit of the TDS amount and the amendment made to Section 276B in the Finance Act, 2024, allowing such delayed deposits. Consequently, the cognizance orders passed by the Special Judge, Economic Offenses, against the petitioners were quashed.
The High Court quashed the criminal proceedings and cognizance orders against the petitioners for offenses u/ss 276B and 278B of the Income Tax Act. The TDS amount in question, which was the subject matter of the economic offense cases and C.O. Case, had already been deposited belatedly with interest to the Income Tax Department. The court held that continuing the proceedings would amount to an abuse of the process of law, given the deposit of the TDS amount and the amendment made to Section 276B in the Finance Act, 2024, allowing such delayed deposits. Consequently, the cognizance orders passed by the Special Judge, Economic Offenses, against the petitioners were quashed.
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