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 HC held that it can exercise inherent powers to compound the offence u/s 138 of the Negotiable Instruments Act at the revisional stage based on a compromise between parties. Despite dismissal of appeal upholding conviction, the HC can intervene to prevent miscarriage of justice. Section 147 of NI Act allows settlement irrespective of CrPC provisions. The conviction and sentence were annulled by invoking inherent powers to secure ends of justice based on the compromise.
The HC held that it can exercise inherent powers to compound the offence u/s 138 of the Negotiable Instruments Act at the revisional stage based on a compromise between parties. Despite dismissal of appeal upholding conviction, the HC can intervene to prevent miscarriage of justice. Section 147 of NI Act allows settlement irrespective of CrPC provisions. The conviction and sentence were annulled by invoking inherent powers to secure ends of justice based on the compromise.
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